Coker v. Jarden
Christopher Paul Coker v. Warden Jarden, Rochester FMC and the Attorney General of the United States
- Bullard
- 0:26-cv-02506
- U.S. District Court · District of Minnesota
- 4
In Coker v. Warden Jarden, Magistrate Judge Bullard recommended denying habeas relief and dismissing the case over release-credit and placement claims.
The recommendation directly affects Christopher Paul Coker’s request for First Step Act time credits and earlier prerelease placement; it also concerns the Bureau of Prisons’ authority over those matters.
What happened
Christopher Paul Coker, who is serving a federal sentence at the Federal Medical Center in Rochester, Minnesota, filed this case against Warden Jarden, Rochester FMC, and the Attorney General of the United States. He argued that the Bureau of Prisons unlawfully refused to award him release credits under the First Step Act and failed to transfer him to prerelease custody as soon as possible under the Second Chance Act.
The court concluded that Coker could not receive First Step Act credits because his conviction was under a statute involving child pornography, which the Act excludes. It also concluded that his Second Chance Act request could not be decided through a habeas petition because that law concerns placement near the end of a sentence, not the length of custody, and the Bureau of Prisons controls prisoner placement.
Magistrate Judge Elsa M. Bullard recommended that Coker’s petition be denied and the case be dismissed. The document is a report and recommendation, not a final order, and it states that objections may be filed within the specified time.
The detailed version
- Coker v. Jarden · No. 0:26-cv-02506
- Bullard
- May 18, 2026
Background
Christopher Paul Coker pleaded guilty in 2017 to receiving and distributing child pornography in violation of 18 U.S.C. §§ 2252A(a)(2)(A) and 2252A(b)(1). He is serving that sentence at the Federal Medical Center in Rochester, Minnesota. Coker filed a petition for a writ of habeas corpus, asking the court to address the Bureau of Prisons’ handling of his possible release-related benefits.
The petition raised two claims. First, Coker argued that he should receive earned time credits under the First Step Act of 2018. Second, he argued that he should receive the earliest possible transfer to prerelease custody under the Second Chance Act of 2007.
First Step Act credits
The court determined that Coker is ineligible for First Step Act time credits. The statute excludes a prisoner serving a sentence for a conviction under 18 U.S.C. § 2252A, which covers certain offenses involving material containing child pornography. Because Coker is serving a sentence for a conviction under that statute, the court concluded that the Bureau of Prisons lawfully could not award him those credits under the statute’s plain language.
Second Chance Act placement
The court noted that Coker is not statutorily barred from transfer to prerelease custody under 18 U.S.C. § 3624(c). But it concluded that his challenge was not a claim that could be resolved through habeas review. The court explained that the Second Chance Act addresses where a prisoner may be placed during the final portion of the sentence, rather than how long the prisoner remains in custody. It therefore concluded that a claim seeking earlier prerelease placement under that Act is not cognizable in a habeas case.
The court also explained that federal law gives the Bureau of Prisons exclusive authority to decide where prisoners are placed while they remain in Bureau custody. It concluded that the Second Chance Act did not limit that authority.
Recommendation and procedure
Magistrate Judge Elsa M. Bullard recommended that Coker’s habeas petition be denied and that the case be dismissed. The recommendation states those as separate proposed dispositions: the petition would be denied, and the case would be dismissed.
The document is a report and recommendation rather than an order or judgment of the District Court. It states that it is not directly appealable to the Court of Appeals and that a party may file specific written objections within 14 days after being served with the recommendation.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.