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United States v. Mettetal

United States District Court, W.D. Virginia, Charlottesville Division

June 22, 2016

United States of America,
Ray Wallace Mettetal, Defendant



         Judge Norman K. Moon This case is presently before the Court upon Defendant's motion for expungement (docket no. 359). Because the Court lacks jurisdiction to rule on Mettetal's claim, his motion will be denied.

         I. Background

         Mett was convicted by a jury in July 1998 for possessing a toxin in violation of 18 U.S.C. § 175 and for possessing false identification documents in violation of 18 U.S.C. § 1028(a)(3). The Fourth Circuit overturned Mettetal's conviction because the evidence used at trial against him "should have been excluded as the fruit of [an] unlawful arrest." United States v. Mettetal, 213 F.3d 634, 2000 WL 530330, at *6 (4th Cir. May 3, 2000) (unpublished).

         On remand, the district court again admitted the evidence against Mettetal, reasoning that it was admissible under the "good faith" exception. Mett was convicted in 2001, but the Fourth Circuit again overturned the conviction, finding that all evidence discovered as a result of Mettetal's unlawful arrest was inadmissible. See United States v. Mettetal, 48 Fed.Appx. 895, 897 (4th Cir. 2002).

         The United States filed a motion to dismiss the indictment against Mett on December 2, 2002, and this Court granted the motion on December 10, 2002.

         Mett asks the Court to expunge his criminal record "and should also order the FBI to expunge/correct its criminal records . . . ." Docket No. 359, at 2. Mett emphasizes that he has no other convictions and that it has been 20 years since he was first unlawfully arrested. Mett claims "he continues to be harassed by the local medical community and has been unable to obtain hospital privileges due to the existence of adverse information on his record." Id. He has also been denied the right to acquire a handgun license in Tennessee, because he claims his "FBI record makes no mention of the fact that the conviction was overturned and the charges subsequently dismissed." Id.

         II. Jurisdiction

         As an initial matter, the Court must determine whether it has jurisdiction to decide Mettetal's claim. Where a party seeks to adjudicate in federal court, the party "must demonstrate the federal court's jurisdiction over the matter." Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546, 552 (2005). Otherwise, without jurisdiction, a court may not rule on the merits of the claim. See Goldsmith v. Baltimore, 845 F.2d 61, 63-64 (4th Cir. 1989) (citing Johnson v. Town of Elizabethtown, 800 F.2d 404, 407 n.2) (4th Cir. 1986)). In determining whether the Court has jurisdiction, it must bear in mind that federal courts "possess only that power authorized by the Constitution and statute, which is not to be expanded by judicial decree." Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (internal citations omitted).

         Courts have the statutory power to expunge documents relating to a criminal charge in only narrow situations not applicable here. See, e.g., 18 U.S.C. § 3607(c) (first offender under Controlled Substances Act). Accordingly, Congress has not directly provided federal district courts with jurisdiction to expunge records for equitable reasons, and "the absence of explicit jurisdictional authorization is notable in light of Congress's decision to provide for an expungement remedy in other narrowly and specifically defined circumstances not applicable here." United States v. Mitchell, 683 F.Supp.2d 427, 432 (E.D. Va. 2010). Moreover, "[t]here is no dispute that the power to expunge federal criminal convictions solely on equitable grounds is [not] explicitly authorized by the[] Constitution . . . ." Id. at 429.

         Nevertheless, the Supreme Court has held that district courts may, in some circumstances, have ancillary jurisdiction over a claim, which grants jurisdiction to district courts over "some matters (otherwise beyond their competence) that are incidental to other matters properly before them." Kokkonen, 511 U.S. at 378-79; see also 13 Charles Alan Wright, Arthur R. Miller, Edward H. Cooper & Richard D. Freer, Federal Practice and Procedure § 3523.2, at 213 (3d ed. 2008) (ancillary jurisdiction exists where a district court "acquires jurisdiction of a case or controversy in its entirety, and, as an incident to the full disposition of the matter, may hear collateral proceedings when necessary to allow it to vindicate its role as a tribunal.").

         The Supreme Court in Kokkonen clarified the scope of ancillary jurisdiction, concluding that it exists in only two circumstances: (1) where necessary "to permit disposition by a single court of claims that are, in varying respects and degrees, factually interdependent"; and (2) "to enable a court to function successfully, that is, to manage its proceedings, vindicate its authority and effectuate its decrees." Kokkonen, 511 U.S. at 379-80.

         Before the Supreme Court decided Kokkonen in 1994, some courts found that they had the equitable power to expunge court records. See, e.g., United States v. Van Wagner, 746 F.Supp. 619, 620-21 (E.D. Va. 1990). Since Kokkonen, neither the Supreme Court nor the Fourth Circuit have "directly addressed the jurisdiction to expunge a criminal record on equitable grounds." United States v. Taylor, Crim. No. 3:12mj230, 2014 WL 1713485, at *2 (E.D. Va. April 29, 2014) (unpublished).

         Other Courts of Appeals have generally found that Kokkonen prevents courts from exercising jurisdiction over equitable expungement motions. See, e.g., United States v. Coloian, 480 F.3d 47, 52 (1st Cir. 2007) ("Thus, Kokkonen forecloses any ancillary jurisdiction to order expungement based on . . . equitable reasons."); United States v. Meyer, 439 F.3d 855, 862 (8th Cir. 2006) ("[I]n light of Kokkonen, we conclude that ancillary jurisdiction does ...

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