Reported / Citable
Background
Stephen H. Spisak, Jr., a Texas inmate proceeding without counsel, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. He was confined at the Lewis Unit in Woodville, within the Eastern District of Texas.
Spisak challenged two aggravated-sexual-assault convictions entered on July 22, 2025, by the 478th District Court for Bell County, Texas. He was sentenced to a term of fifty years’ confinement. Bell County is within the Waco Division of the U.S. District Court for the Western District of Texas.
The Court’s Holding
The court ordered the petition transferred to the Western District of Texas, Waco Division. Although jurisdiction was proper in the Eastern District because Spisak was confined within that district, 28 U.S.C. § 2241(d) allowed the court to transfer the action to the district where he was convicted when doing so would further the interests of justice.
The court determined that transfer would further justice because the challenged convictions occurred in the Waco Division and the relevant records and witnesses may be located in the Western District. It also cited 28 U.S.C. § 1404(a), which permits transfer for the convenience of parties and witnesses and in the interest of justice, including on the court’s own initiative.
Key Takeaways
- A state prisoner may file a federal habeas petition in the district of confinement or the district of conviction under 28 U.S.C. § 2241(d).
- The Eastern District had jurisdiction because Spisak was confined within its territorial boundaries.
- The court transferred the case to the Waco Division because the convictions occurred there and relevant records and witnesses may be located in the Western District.
Why It Matters
The order illustrates that a court with jurisdiction over a habeas petition may still transfer it to the district of conviction when the case-specific circumstances favor that forum. Here, the location of the convictions and the possible location of records and witnesses supported transfer in the interest of justice.