Ex Parte Hull

Cleio Hull (plaintiff) was incarcerated in a Michigan prison. The prison had a rule that all legal documents, including habeas corpus petitions, had to be submitted to the prison’s welfare office for review. If the papers’ form and allegations were deemed sufficient, the papers would then be passed along to a state investigator for further review. If the investigator believed the form and allegations were sufficient, they could then be filed with a court. However, if either level of review found that the papers had deficiencies, they would be returned to the prisoner. Hull prepared a petition for a writ of habeas corpus to file with a federal district court in order to contest the legality of his imprisonment. Hull asked a prison official to notarize the papers. The official refused to notarize the petition papers and informed Hull that the prison would not accept the papers for mailing. Hull then gave the unnotarized papers to his father to mail, but the prison guards confiscated the papers. Hull tried mailing a letter to the clerk of court about his difficulties, but the prison intercepted the letter and sent it to a state investigator. The investigator wrote Hull to inform him that the letter was not a valid habeas petition and to provide him with information about what was necessary for papers to be a valid habeas corpus petition. Hull drew up new petition papers setting out his filing difficulties and his arguments for wrongful imprisonment and managed to get them to his father, who filed the papers with the clerk of the United States Supreme Court. The Court considered the petition.