Robinson v. Davis
- Michael Davis
- 0:25-cv-02271
- U.S. District Court · District of Minnesota
- 5
In Robinson v. Davis, Judge Docherty recommended denying Robinson’s transfer petition and dismissing it without prejudice.
Alicia L. Robinson, who sought an immediate transfer to home confinement or a residential reentry center; the recommendation leaves the BOP’s placement decision in place.
What happened
In Robinson v. Davis, Alicia L. Robinson asked the court to order the Bureau of Prisons to transfer her from prison to home confinement or a halfway house. She argued that the Second Chance Act and First Step Act entitled her to an earlier transfer.
The recommendation explained that the Bureau of Prisons—not the court—has authority to decide prisoner placement under the Second Chance Act. Robinson did not claim that the Bureau had miscalculated or improperly applied her earned time credits; instead, she challenged the timing of her residential reentry center placement.
Judge John F. Docherty recommended denying Robinson’s habeas petition and dismissing the matter without prejudice because she had not stated a claim the court could grant under the Second Chance Act. The report says it was a recommendation, not a directly appealable district-court order, and allowed objections within the stated time.
The detailed version
- Robinson v. Davis · No. 0:25-cv-02271
- Michael Davis
- June 25, 2025
Background
Alicia L. Robinson filed a petition under 28 U.S.C. § 2241 asking the court to order the Bureau of Prisons (BOP) to transfer her immediately to home confinement or a residential reentry center (RRC), commonly called a halfway house. She was serving a 62-month federal sentence at the Federal Correctional Institution in Waseca, Minnesota.
Robinson asserted that she was eligible for an RRC transfer on May 15, 2025, and that her continued imprisonment at that facility violated the Second Chance Act (SCA), 18 U.S.C. § 3624, and the First Step Act (FSA), 18 U.S.C. § 3632. The report states that the BOP had recommended her for 295 days of RRC placement, consisting of 151 to 180 days under the SCA plus projected earned time credits. Robinson apparently did not dispute that calculation.
Analysis
The report distinguished between eligibility for prerelease placement and the BOP’s decision whether to make the placement. The FSA permits eligible prisoners to earn time credits through qualifying programs and activities. Those credits may be used for prerelease custody or, in some circumstances, an earlier start to supervised release. The SCA also addresses home confinement and RRC placement.
The report concluded that Robinson was not actually challenging the BOP’s calculation or application of her FSA time credits. She argued instead that the BOP should transfer her to an RRC earlier under the SCA. The report explained that federal law gives the BOP authority to determine prisoner placement and does not give courts authority to place a prisoner in home confinement or an RRC. It therefore concluded that the BOP’s placement decision was not reviewable under the SCA and that Robinson had not stated a claim for habeas relief.
Recommendation and procedural posture
Judge John F. Docherty recommended that Robinson’s § 2241 petition be denied and that the matter be dismissed without prejudice. The report and recommendation states that it was not an order or judgment of the District Court and therefore was not directly appealable to the U.S. Court of Appeals for the Eighth Circuit. It allowed the parties to file specific written objections within 14 days after service.
Key outcome
- Petition for habeas relief: denied. - Matter: dismissed without prejudice. - Basis: The court cannot order the BOP to make the requested placement, and Robinson did not assert that the BOP improperly calculated or applied her earned time credits.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.