Ohlmeier v. Warden Jared Rardin
- Elizabeth Cowan Wright
- 0:24-cv-04382
- U.S. District Court · District of Minnesota
- 5
In Ohlmeier v. Rardin, Magistrate Judge Wright recommended denying his petition after finding no restitution-based loss of prison credits.
The recommendation affects Todd Allen Ohlmeier’s claim that prison officials improperly denied him good-conduct time because he did not pay restitution, and it addresses Warden Jared Rardin’s response to that claim.
What happened
In Todd Allen Ohlmeier v. Warden Jared Rardin, Ohlmeier challenged prison officials’ efforts to collect restitution while he was incarcerated and claimed that refusing to pay caused him to lose certain benefits, including good-conduct time.
The remaining issue was whether Ohlmeier had improperly lost good-conduct time because he did not pay restitution. The respondent provided evidence that Ohlmeier had not lost any credits for that reason; the only credits he had lost resulted from a 2021 incident involving damage to government property.
Magistrate Judge Elizabeth Cowan Wright recommended denying Ohlmeier’s petition because he did not rebut that evidence. The recommendation is not a final district-court judgment, and the notice allowed the parties to file objections.
The detailed version
- Ohlmeier v. Warden Jared Rardin · No. 0:24-cv-04382
- Elizabeth Cowan Wright
- Apr. 2, 2026
Background
Todd Allen Ohlmeier filed a petition under 28 U.S.C. § 2241, a procedure used to challenge unlawful custody or the execution of a sentence. He is serving a 96-month prison sentence for receiving child pornography and is incarcerated at the Federal Medical Center in Rochester, Minnesota.
Ohlmeier originally raised two challenges involving prison officials’ efforts to collect $300 per month in restitution payments, including a $3,000 assessment under the Amy, Vicky, and Andy Child Pornography Victim Assistance Act. He argued that collecting the payments before supervised release unlawfully changed his sentencing judgment. He also claimed that refusing to comply caused officials to deny him commissary access and good-conduct time.
The court had previously recommended denying the claims about the sentencing judgment and commissary access, while requiring a response to the good-conduct-time claim. The district judge adopted that earlier recommendation, leaving the good-conduct-time issue for decision.
Analysis
The respondent argued that Ohlmeier had not exhausted the prison administrative-remedy process, while also addressing the claim’s merits. The court decided that judicial efficiency favored resolving the claim on the merits rather than deciding exhaustion.
Under 18 U.S.C. § 3624(b), an eligible prisoner may receive up to 54 days of credit for each year of a sentence if the Bureau of Prisons determines that the prisoner has complied satisfactorily with institutional disciplinary rules. The petition alleged that Ohlmeier lost good-conduct time because he failed to pay restitution.
The respondent submitted evidence that Ohlmeier had not lost any good-conduct time because of his restitution conduct. According to that evidence, the only credits he had lost resulted from a November 2021 incident in which he was found responsible for destroying government property, including trying to break a sprinkler. Ohlmeier’s petition did not challenge that loss of credits, and his reply did not rebut the respondent’s evidence or address good-conduct time. The court therefore found that no evidentiary hearing was necessary.
Recommendation and procedural status
Judge Elizabeth Cowan Wright recommended that Ohlmeier’s § 2241 petition be denied. The document is a magistrate judge’s report and recommendation, not a final district-court order or judgment. The notice states that either party could file specific written objections within 14 days after being served.
Disposition
Recommended: Petition for a writ of habeas corpus under 28 U.S.C. § 2241 DENIED.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.