Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Sixth Circuit: Tyganda Gilmore v. David Ebbert
A prisoner seeking habeas relief from an unlawful detainer must seek habeas against the jurisdiction holding the detainer against his or her future release, not the jurisdiction of present incarceration.