Warren v. Molis

Background

Elaine Warren filed a petition under 28 U.S.C. § 2241 challenging the Federal Bureau of Prisons’ decision not to apply earned-time credits that she claimed to have earned. The report states that Warren is incarcerated at FCI Waseca and that her claims concern her Medium score under PATTERN, a Bureau of Prisons risk-and-needs assessment tool used in determining eligibility for earned-time credits.

The filing raised four grounds for relief. The magistrate judge understood Ground 1 as challenging Warren’s inability to reduce her Medium PATTERN score despite completing substantial programming. Ground 2 alleged that the Bureau of Prisons delayed her entry into programming that might have reduced her score. Ground 3 appeared to challenge the warden’s denial of Warren’s request for an exception allowing earned-time credits to be applied despite her Medium score. Ground 4 appeared to argue that her clean disciplinary record should have supported granting that request.

Analysis

For Grounds 1 and 2, the report concluded that Warren identified neither a statutory right to a particular PATTERN score nor a statutory or constitutional right to participate in specific programming. Relying on Supreme Court precedent concerning prisoner classification and access to rehabilitative programs, the report stated that these challenges were not claims that could be decided through a habeas petition.

For Ground 3, the report explained that 18 U.S.C. § 3624(g)(1)(D)(i)(II) permits a warden, after individualized review, to approve an early transfer to prerelease custody for an inmate with a Medium or High PATTERN score if the statutory conditions are met. The materials submitted with the petition indicated that Warren had requested this treatment and that the warden denied the request in December 2024 because of her minor history of escape. The report concluded that 18 U.S.C. § 3625 bars federal courts from reviewing Bureau of Prisons determinations made under the relevant prisoner-confinement statutes, including this discretionary decision.

The report treated Ground 4 as another challenge to the warden’s decision and reached the same conclusion: the court lacked authority to revisit that discretionary determination. The report also noted that nothing in the petition suggested Warren was claiming that individualized review had not occurred.

Disposition

Magistrate Judge Elsa M. Bullard recommended that Warren’s petition be DENIED and that the action be DISMISSED. Because this was a report and recommendation rather than a final district-court order, the document stated that it was not directly appealable to the U.S. Court of Appeals for the Eighth Circuit. It further stated that a party could file specific written objections within 14 days after being served with the report and recommendation. The opinion text does not state whether the district judge later adopted the recommendation.