Lopez-Campanella v. United States
- Eric Tostrud
- 0:25-cv-01694
- U.S. District Court · District of Minnesota
- 5
In Lopez-Campanella v. United States, Judge Schultz recommended denying habeas relief because the petitioner did not establish eligibility for First Step Act credits.
Juan Guillerm Lopez-Campanella, a federal prisoner seeking First Step Act time credits and release; the recommendation also concerns the Federal Bureau of Prisons’ treatment of those credits.
What happened
Juan Guillerm Lopez-Campanella, a federal prisoner, asked for the return of time credits and his immediate release. Although he called them “good time” credits, the court understood his request to concern credits under the First Step Act.
The court explained that the First Step Act excludes prisoners subject to a final removal order from using those credits to shorten their sentences. Lopez-Campanella relied on an alleged new law that supposedly changed this rule, but the court found that the provision remained in effect and that he pleaded no other facts showing eligibility.
In the Report and Recommendation signed by Judge David T. Schultz, the court recommended that the habeas petition be denied and the matter dismissed. The recommendation was not yet a final, directly appealable order, and the notice allowed written objections within 14 days after service.
The detailed version
- Lopez-Campanella v. United States · No. 0:25-cv-01694
- Eric Tostrud
- May 8, 2025
Background
Juan Guillerm Lopez-Campanella is a federal prisoner serving a sentence imposed by the U.S. District Court for the Middle District of Florida after he pleaded guilty to a drug offense. The opinion states that he was serving the final months of his sentence at the Federal Medical Center in Rochester, Minnesota.
Lopez-Campanella filed a petition for a writ of habeas corpus, asking for the return of time credits and stating that receiving those credits would require his immediate release. The petition referred to “good time” credits but also cited the First Step Act of 2018. The court interpreted the petition as seeking relief based on lost or unawarded First Step Act time credits, rather than the ordinary good-time credits available under 18 U.S.C. § 3624(b)(1).
Court’s analysis
The First Step Act permits eligible federal prisoners to earn credits through certain recidivism-reduction programs and productive activities. Those credits may be applied to reduce a sentence by up to one year. But 18 U.S.C. § 3632(d)(4)(E) excludes prisoners who are subject to a final order of removal under the immigration laws from applying those credits toward their sentences.
The court held that Lopez-Campanella had not pleaded facts establishing his eligibility for First Step Act credits. He alleged that new legislation made deportable people eligible, but the court found that allegation legally untrue because the exclusion in § 3632(d)(4)(E) remained in effect. He alleged no other facts establishing eligibility. The court therefore concluded that it had no basis to find that the Federal Bureau of Prisons had detained, or intended to detain, him longer than legally permitted.
Recommendation and procedural status
The court recommended that Lopez-Campanella’s habeas petition be DENIED and that the matter be DISMISSED. The document is a magistrate judge’s Report and Recommendation, not a final order or judgment of the District Court. The notice stated that it was not directly appealable to the U.S. Court of Appeals for the Eighth Circuit and that a party could file specific written objections within 14 days after being served.
The opinion identifies David T. Schultz as the magistrate judge who signed the Report and Recommendation. The supplied case metadata separately lists Eric Tostrud as the judge, but the opinion text itself is signed by David T. Schultz.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.