Williamson v. Eischen

Background

Van Williamson filed a petition under 28 U.S.C. § 2241 challenging the Bureau of Prisons’ calculation of his First Step Act time credits. He claimed that 165 credits were missing from the credits applied toward transfer to pre-release custody, such as a residential reentry center or home confinement. He asked the court to order the Bureau to add those credits. The Bureau responded that it had correctly calculated his credits at the proper rate.

Williamson did not dispute the credits applied toward early supervised release. His petition concerned only credits toward earlier transfer to pre-release custody. While the petition was pending, he informed the court that the Bureau had released him to a halfway house. The court also reviewed Bureau records indicating that he had been transferred to a residential reentry center.

Legal analysis

The report explained that a federal custody petition under Section 2241 can challenge the fact or duration of confinement. It concluded that Williamson’s request challenged only the place of confinement. Under the cited precedent, placement in a residential reentry center or home confinement is a place-of-confinement decision, not a challenge to the validity or length of custody.

The report further stated that the Bureau of Prisons has exclusive authority to decide prisoner placement and that Williamson had no constitutional right or legal entitlement to placement in a particular facility or to any period in a residential reentry center. Because his claim did not present a challenge for which Section 2241 relief was available, the court concluded that it lacked subject-matter jurisdiction. The report also stated that an evidentiary hearing was unnecessary because the petition did not state a claim cognizable in a federal custody proceeding.

The report noted separately that, even if the claim were legally cognizable, Williamson’s transfer to a residential reentry center appeared to make the request moot because the court could no longer grant the earlier transfer he sought.

Recommended disposition

Magistrate Judge Douglas L. Micko recommended that Williamson’s Section 2241 petition be DENIED and that the matter be DISMISSED WITHOUT PREJUDICE. The document is a report and recommendation, not an order or judgment of the District Court, and it states that it was not directly appealable to the Eighth Circuit. The notice allowed the parties to file written objections within the stated deadlines.