Michael Townes v. United States

── Michael Townes v. United States ── Court: Court of Appeals for the Eleventh Circuit Date: May 28, 2026 Category: NEW USCA11 Case: 26-10049 Document: 16-1 Date Filed: 05/28/2026 Page: 1 of 9 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 26-10049 Non-Argument Calendar ____________________ MICHAEL TOWNES, Plaintiff-Appellant, versus UNITED STATES OF AMERICA, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:25-cv-05742-ELR ____________________ Before NEWSOM, GRANT, and BRASHER, Circuit Judges. PER CURIAM: Michael Townes appeals the dismissal of his complaint for declaratory and injunctive relief as frivolous under 28 U.S.C. § 1915(e)(2)(B). We affirm. USCA11 Case: 26-10049 Document: 16-1 Date Filed: 05/28/2026 Page: 2 of 9 2 Opinion of the Court 26-10049 I. Townes filed a complaint in federal court seeking relief from the “ongoing civil disabilities” arising from his 2018 conviction for transmitting a threat in interstate commerce. See 18 U.S.C. § 875(c). He alleged that his conviction was unconstitutional be- cause the government failed to prove that he had a subjective in- tent to threaten—but he explicitly denied seeking to vacate or ex- punge the conviction. He explained that he had completed his term of imprisonment and was no longer subject to court supervi- sion, meaning that he was unable to obtain the relief he sought by filing a motion to vacate his sentence under 28 U.S.C. § 2255 or a habeas corpus petition under 28 U.S.C. § 2241. And he explicitly declined to pursue a writ of error coram nobis because he did not believe he could meet the stringent requirements for that extraor- dinary remedy. Townes alleged that he suffered ongoing injuries from his conviction, including disqualification from employment and pro- fessional licenses requiring background checks, denial of “rental opportunities and housing access” based on his classification as a violent offender, “risk of disenfranchisement and reduced access to civic participation,” reputational stigma, and the possibility that his sentence for a future offense could be enhanced based on the past conviction. He also alleged that the conviction had caused or could cause “watchlisting” by the Transportation Security Administra- tion and statutory restrictions on his possession of firearms, and he made indecipherable allegations about federal electronic surveil- lance and the deployment of federal troops. USCA11 Case: 26-10049 Document: 16-1 Date Filed: 05/28/2026 Page: 3 of 9 26-10049 Opinion of the Court 3 Townes sued “federal agencies and officials, including but not limited to” the Department of Justice, the Federal Bureau of Investigation, the Bureau of Prisons, and other “federal actors re- sponsible for the investigation, prosecution, classification, or post- sentence enforcement actions affecting Plaintiff.” He stated that he intended to amend his complaint to identify individual federal of- ficers whose acts contributed to the alleged constitutional viola- tions and civil disabilitie