Gunderson v. Federal Medical Center - Rochester
- Jeffrey Bryan
- 0:23-cv-00423
- U.S. District Court · District of Minnesota
- 2
In Gunderson v. Federal Medical Center–Rochester, Judge Bryan dismissed without prejudice Gunderson’s First Step Act time-credit petition after adopting the magistrate judge’s recommendation.
James Gunderson, who sought eligibility to earn First Step Act time credits, and Federal Medical Center–Rochester, the respondent.
What happened
James Gunderson asked the court to rule that he could earn time credits under the First Step Act. The magistrate judge recommended denying the petition because Gunderson’s offense was not eligible for those credits and his sentence could not be divided into eligible and ineligible portions.
Neither side objected to the recommendation. The court therefore reviewed it for clear error, meaning an obvious mistake, and found none.
Judge Jeffrey M. Bryan adopted the recommendation and dismissed the action without prejudice. The opinion does not provide additional analysis of the time-credit issue beyond the reasons summarized from the recommendation.
The detailed version
- Gunderson v. Federal Medical Center - Rochester · No. 0:23-cv-00423
- Jeffrey M. Bryan
- July 2, 2025
Background
James Gunderson, who represented himself, filed a petition asking the court to determine that he was eligible to earn First Step Act time credits. The respondent was Federal Medical Center–Rochester.
Report and Recommendation
United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation dated May 30, 2025. It recommended denying Gunderson’s petition because he was serving a sentence for an offense that was ineligible for First Step Act time credits and because his sentence could not be divided into segments that were eligible to earn those credits.
Court’s Review and Ruling
Neither party objected to the Report and Recommendation. The court therefore reviewed it for clear error, an obvious mistake in the recommendation. The court found no clear error, adopted the Report and Recommendation, and dismissed the action without 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.