Pittman v. Rardin
- Susan Nelson
- 0:26-cv-01662
- U.S. District Court · District of Minnesota
- 6
In Pittman v. Rardin, Judge Nelson denied the time-credit petition, dismissed the case, and denied the sealing request.
The ruling directly affected Earnest Lee Pittman, Jr.’s request for earned time credits, his request to seal the case record, and his application to proceed without prepaying fees or costs. The case caption was changed to identify Warden Jared Rardin as the sole respondent.
What happened
Earnest Lee Pittman, Jr. v. Jared Rardin concerned Pittman’s request for earned time credits for the period between his federal sentencing and arrival at his designated prison facility. He argued that the Bureau of Prisons should award credits for that 94-day period and that doing so could lead to earlier home confinement.
Pittman acknowledged that he did not participate in qualifying recidivism-reduction programming or productive activities during that period. He argued that the Bureau of Prisons should not deny credits because it failed to offer programming. He also asked the court to seal the entire case record.
Judge Susan Richard Nelson overruled Pittman’s objections, adopted the magistrate judge’s recommendation, denied the petition, dismissed the case, and denied his fee application as moot. The court also denied the request to seal the record and changed the caption to identify Warden Jared Rardin as the sole respondent.
The detailed version
- Pittman v. Rardin · No. 0:26-cv-01662
- Susan Nelson
- June 3, 2026
Background
In December 2021, the U.S. District Court for the Middle District of Pennsylvania sentenced Earnest Lee Pittman, Jr. to 120 months in prison. The Bureau of Prisons did not transfer him to his designated facility, FCI-Forrest City, until March 18, 2022. Pittman was later housed at FMC-Rochester.
Pittman filed a petition seeking earned time credits for the period from December 14, 2021, through his arrival at FCI-Forrest City. Under 18 U.S.C. § 3632(d)(4)(A), prisoners earn these credits after successfully completing evidence-based recidivism-reduction programming or productive activities. Pittman claimed that the 94-day period cost him 30 to 45 days of credits and sought an earlier release to home confinement. He also asked the court to seal the entire record.
Report and Recommendation and Objections
The magistrate judge identified a possible conflict between the federal statute governing sentence commencement and a Bureau of Prisons regulation stating that earned time credits may be earned only after an inmate arrives or voluntarily surrenders at the designated facility. The magistrate judge did not resolve that conflict because Pittman had not alleged that he participated in qualifying programming during the relevant period.
Pittman objected that he should not lose credits because the Bureau of Prisons failed to offer programming. He argued that he would have participated if qualifying programming had been offered. The magistrate judge also recommended denying the request to seal the entire record because it was too broad.
Court’s Ruling
After reviewing the objections, the court adopted the Report and Recommendation. The court stated that Pittman conceded he did not participate in qualifying programming between his sentencing and arrival at FCI-Forrest City. Because participation was a legal precondition for receiving earned time credits, the court held that it could not award the requested credits. The court noted Pittman’s later participation in programming and productive activities and his apparent lack of disciplinary history, but said those facts did not permit the requested relief.
The court overruled Pittman’s objections, adopted the April 1, 2026 Report and Recommendation, denied the habeas petition, and dismissed the action. It denied Pittman’s application to proceed without prepaying fees or costs as moot. The court separately denied the request to seal the entire record, finding that a blanket sealing request was too broad under the local rules and that Pittman had not identified specific passages for redaction or proposed a focused sealing request. The court also modified the caption to identify Warden Jared Rardin as the sole respondent.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.