Brown v. Eischen
- Katherine Menendez
- 0:25-cv-00171
- U.S. District Court · District of Minnesota
- 2
In Brown v. Eischen, Judge Menendez denied Steven Dejuan Brown’s habeas petition, agreeing he was not entitled to First Step Act earned-time credits.
Steven Dejuan Brown, whose request for First Step Act earned-time credits was denied; the Bureau of Prisons’ refusal to award those credits was upheld.
What happened
In Brown v. Eischen, Steven Dejuan Brown asked the court to order the Bureau of Prisons to award him earned-time credits under the First Step Act of 2018. He alleged that the Bureau was wrongfully refusing to award the credits.
A magistrate judge recommended denying the petition because Brown was convicted under Section 924(c) and therefore was not entitled to the credits. Brown did not object to that recommendation. The court reviewed it for clear error and found none.
Judge Katherine Menendez accepted the recommendation, denied Brown’s petition, and dismissed the matter with prejudice. The order directed that judgment be entered accordingly.
The detailed version
- Brown v. Eischen · No. 0:25-cv-00171
- Katherine Menendez
- May 28, 2025
Background
Steven Dejuan Brown filed a petition for a writ of habeas corpus, a request challenging the lawfulness of his federal custody or the way his sentence was being carried out. He alleged that the Federal Bureau of Prisons wrongfully refused to award him earned-time credits under the First Step Act of 2018.
Report and Recommendation
Magistrate Judge Dulce J. Foster recommended that the petition be denied. The recommendation stated that Brown was convicted under Section 924(c), was not entitled to First Step Act time credits, and that the Bureau of Prisons acted consistently with the law by declining to award them.
Brown filed no objections within the permitted time. Because there were no objections, the district court reviewed the recommendation for clear error rather than conducting a fresh review of the disputed issues. The court found no error, clear or otherwise.
Ruling
Judge Katherine Menendez accepted the magistrate judge’s Report and Recommendation, denied Brown’s petition for a writ of habeas corpus, and dismissed the matter with prejudice. The court ordered that judgment be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.