Constitutional Law—Supreme Court Avoids Lawfulness of Enemy Combatants’ Detention by Resolving Case on Jurisdictional Grounds—Rumsfeld v. Padilla, 124 S. Ct. 2711 (2004)

The habeas corpus writ offers a last resort for petitioners seeking to raise their right to be free from wrongful restraints upon their liberty.  To avoid dismissal, the petitioner must not only file a habeas petition in the appropriate jurisdiction, but also name the proper respondent—two selections that are not always clear from the outset of the case.  In Rumsfeld v. Padilla, the Supreme Court of the United States considered whether an enemy combatant, Jose Padilla, properly filed a habeas corpus writ pursuant to 28 U.S.C. § 2241, and whether the President of the United States possesses authority to detain Padilla.  The Supreme Court held in a 5-4 decision that the United States District Court for the Southern District of New York (SDNY) did not have jurisdiction over Padilla’s habeas petition, and therefore the Court did not reach the merits of Padilla’s challenge to the lawfulness of his detention. . . .