Hoffman v. Warden
- Katherine Menendez
- 0:24-cv-04344
- U.S. District Court · District of Minnesota
- 4
In Hoffman v. Warden, Judge Menendez denied the petition, dismissing some claims with prejudice and the prerelease-credit claim without prejudice for lack of standing.
Michael Hoffman’s petition was denied. His claim that he was already entitled to a past Conditional Transition to Community Date was dismissed with prejudice, while his claim concerning First Step Act credits during prerelease custody was dismissed without prejudice for lack of standing.
What happened
Michael Hoffman challenged the Bureau of Prisons’ calculations of his good-conduct time, First Step Act time credits, and Second Chance Act credits, which affect when he could enter prerelease custody. He sought a declaration setting that date as October 23, 2024, February 6, 2025, or another date.
The court found that Mr. Hoffman’s October 23, 2024 calculation incorrectly assumed he would earn the maximum possible First Step Act credits and could keep earning them past his projected release date. Because his future credits were uncertain, the court concluded that he had not shown a current injury giving him standing to bring the claim.
Judge Menendez adopted the magistrate judge’s recommendation and denied the amended petition. The claim that Mr. Hoffman was already entitled to prerelease custody was dismissed with prejudice, while his claim that he could earn First Step Act credits while in prerelease custody was dismissed without prejudice because he lacked standing to raise it yet.
The detailed version
- Hoffman v. Warden · No. 0:24-cv-04344
- Katherine Menendez
- Apr. 29, 2026
Background
Michael Hoffman filed an amended petition for a writ of habeas corpus, a court challenge to the legality of his custody or the calculation of his release-related date. He alleged that the Bureau of Prisons miscalculated his good-conduct time, First Step Act time credits (FTCs), and Second Chance Act credits. He said those calculations affected his “Conditional Transition to Community Date,” meaning when he would become eligible for transfer to prerelease custody.
Mr. Hoffman asked the court to declare that date October 23, 2024, February 6, 2025, or another date determined by the court. Magistrate Judge Shannon G. Elkins recommended denying the amended petition and dismissing the matter. Mr. Hoffman objected, so Judge Menendez reviewed the challenged portions of the recommendation anew and reviewed the entire recommendation because Mr. Hoffman objected to it “in its entirety.”
Court’s Analysis
The court agreed that Mr. Hoffman’s self-calculated October 23, 2024 date contained errors. The calculation assumed that he would earn the maximum possible number of FTCs and remain eligible to earn those credits after his projected release date. Because the total number of FTCs he would earn in the future was speculative and could not yet be calculated, the court concluded that he had not shown a current injury in fact. Without such an injury, he lacked standing to bring the claim at that time.
The court declined to decide whether prisoners may continue earning FTCs while serving their sentences in prerelease custody. It stated that Mr. Hoffman could later pursue a claim if he established that he had participated in programming during prerelease custody and was being denied credits.
Disposition
The court accepted the magistrate judge’s report and recommendation and denied Mr. Hoffman’s amended petition. It dismissed with prejudice the portion claiming that he was entitled to a Conditional Transition to Community Date that had already passed. It dismissed without prejudice, for lack of standing, the remaining claim—including the claim that he could earn FTCs while in prerelease custody. The opinion noted an estimate that his transition-to-community date could be May 27, 2026 under a best-case scenario, but it did not decide the unresolved prerelease-credit issue.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.