Restricting §2241 Habeas Claims for Unauthorized Successive §2254 Petitions: Eaves v. Stancil

Introduction

In Eaves v. Stancil, the United States Court of Appeals for the Tenth Circuit denied a certificate of appealability (COA) for petitioner Rodney Douglas Eaves’s attempt to challenge his state‐court restitution order under 28 U.S.C. § 2241. Eaves, a Colorado prisoner, sought federal relief from a restitution judgment he characterized as unlawfully imposing interest while he was incarcerated. The district court dismissed the petition as an unauthorized second or successive habeas application under 28 U.S.C. § 2254, and the Tenth Circuit affirmed. The decision reinforces the boundary between § 2241 (execution challenges) and § 2254 (validity challenges) and underscores the procedural requirement of obtaining circuit-court authorization before filing a successive § 2254 petition.

Case Background and Key Issues

In 2016, a Colorado jury convicted Eaves of aggravated robbery, theft, menacing, and weapons charges. The trial court sentenced him to 30 years in prison and ordered restitution of $40,140.78—with 8% annual interest—from the date of entry. After unsuccessful direct appeals and state post-conviction relief, Eaves first filed a § 2254 habeas application in 2018, which was denied. In 2024, he filed a new petition in federal district court, styled under § 2241, raising three distinct claims:

The state court lacked jurisdiction to order restitution to the victim’s insurer.
The restitution amount to the victim exceeded actual pecuniary loss.
The imposition of interest on restitution while incarcerated violated Colorado law.

The State moved to dismiss on procedural grounds, asserting the petition was an unauthorized successive § 2254 application. The magistrate judge and district court agreed, and Eaves appealed, seeking a COA.

Summary of the Judgment

The Tenth Circuit held that Eaves’s petition, although styled under § 2241, in reality challenged the validity of his restitution sentence rather than its execution. Because he had previously litigated similar claims in his 2018 § 2254 petition, this new filing was “second or successive” and required prior circuit authorization under 28 U.S.C. § 2244(b)(3). Eaves had obtained no such authorization; accordingly, the district court lacked jurisdiction to consider the merits. The court further treated Eaves’s third claim (interest accrual) as a state‐law issue that did not allege deprivation of any federal constitutional right. Because reasonable jurists would not debate the procedural dismissal or the absence of a federal constitutional claim, the Tenth Circuit denied a COA and dismissed the appeal.

Analysis

Precedents Cited

Licon v. Ledezma (638 F.3d 1303, 10th Cir. 2011): Interprets pro se filings liberally.
Slack v. McDaniel (529 U.S. 473, 2000): Establishes the two‐part COA test for procedural dismissals—that jurists of reason could debate both the constitutional claim and the correctness of the procedural ruling.
In re Cline (531 F.3d 1249, 10th Cir. 2008): Holds district courts lack jurisdiction over unauthorized second or successive § 2254 petitions.
Paredes v. Atherton (224 F.3d 1160, 10th Cir. 2000): Describes the “quick look” approach to assess whether a habeas petition facially alleges a federal constitutional violation.
Leatherwood v. Allbaugh (861 F.3d 1034, 10th Cir. 2017): Reiterates that federal habeas relief cannot be used to correct errors of state law.
In re Weathersby (717 F.3d 1108, 10th Cir. 2013): Defines the ripeness exception for successive petitions based on newly arising claims.

Legal Reasoning

The court’s reasoning hinges on the distinction between challenges to execution of a sentence (§ 2241) and to its validity (§ 2254). Eaves’s challenge to the restitution order sought to invalidate part of his sentence rather than change the mechanics of its enforcement. Under 28 U.S.C. § 2244(b)(3), any second or successive § 2254 petition requires prior authorization from the appropriate circuit court. Because Eaves had already filed a § 2254 petition attacking his restitution order, the district court properly treated the new filing as successive and dismissed for lack of jurisdiction.

As to the alleged Fourteenth Amendment due‐process violation in his interest‐on‐restitution claim, the court applied the “quick look” test and found that Eaves did not invoke any specific federal constitutional provision supported by factual allegations. The dispute concerned state statutory interpretation, not a deprivation of federal right, removing any basis for habeas relief.

Impact

Although nonbinding as precedent under Tenth Circuit Rule 32.1, this decision carries persuasive weight. It reaffirms:

The strict separation between § 2241 and § 2254 relief and the import of labeling a petition “execution” versus “validity.”
The requirement of obtaining circuit‐court authorization before filing any successive § 2254 petition—even if recast as § 2241—thereby curbing forum‐shopping by state prisoners.
The principle that state‐law errors, absent violation of a specific federal guarantee, are not grounds for federal habeas corpus relief.

Future litigants will face higher hurdles when seeking to relitigate state‐court sentencing or restitution issues in federal court without first securing authorization.

Complex Concepts Simplified

§ 2241 vs. § 2254: § 2241 petitions challenge the execution of a sentence (e.g., parole, jail conditions), whereas § 2254 petitions challenge the validity of a state‐court conviction or sentence.
Second or Successive Petition: Under 28 U.S.C. § 2244(b), once a federal habeas petition has been adjudicated, any new petition challenging the same conviction or sentence counts as “second or successive.” Such petitions must be authorized by the appellate court before a district court can reach the merits.
Certificate of Appealability (COA): A COA is required to appeal the denial of a habeas petition. Under Slack v. McDaniel, when a petition is dismissed on procedural grounds, the applicant must show (1) a debatable constitutional claim and (2) a debatable problem with the procedural ruling.

Conclusion

Eaves v. Stancil serves as a clear reminder that state prisoners cannot evade the procedural bar on successive habeas petitions by relabeling them under § 2241. Challenges to restitution orders—and similar sentencing issues—remain subject to the strictures of § 2254 and the requirement of prior circuit authorization. The decision underscores the limited role of federal habeas corpus in correcting state‐law sentencing errors and clarifies the jurisdictional boundaries that protect judicial resources and finality of state‐court judgments.