Henry v. Jenkins
- Vince Chhabria
- 3:20-cv-01532
- U.S. District Court · Northern District of California
- 3
In Henry v. Jenkins, Judge Chhabria dismissed Henry’s sentence-reduction challenge with prejudice because the court lacked jurisdiction.
Maria Laren Henry, an inmate challenging the Bureau of Prisons’ denial of an RDAP-related sentence reduction, was affected. The respondent’s motion to dismiss was granted, and Henry’s case was dismissed with prejudice for lack of jurisdiction.
What happened
In Maria Laren Henry v. W.Z. Jenkins, Maria Laren Henry, who represented herself, challenged the Bureau of Prisons’ decision denying her a possible one-year sentence reduction after she completed a drug-treatment program. The Bureau had determined that her firearm-related sentence enhancement made her ineligible.
The court held that it lacked jurisdiction because Henry’s challenge depended on the specific facts of her case, including how the firearm was considered. The court relied on Ninth Circuit precedent stating that courts generally cannot review the Bureau’s individual decisions about sentence reductions under this program.
Judge Vince Chhabria granted the respondent’s motion to dismiss for lack of jurisdiction and dismissed the case with prejudice because amendment would be futile. The clerk was ordered to enter a separate judgment and close the file.
The detailed version
- Henry v. Jenkins · No. 3:20-cv-01532
- Vince Chhabria
- Dec. 29, 2020
Background
Maria Laren Henry, an inmate at the Federal Correctional Institution in Dublin, California, filed a self-represented petition for a writ of habeas corpus under 28 U.S.C. § 2241. A habeas petition is a request for a court order concerning the legality of a person’s custody. Henry challenged the Bureau of Prisons’ decision that she was not eligible for a sentence reduction after completing the Bureau’s Residential Drug Abuse Program, or RDAP.
Henry was serving a 70-month sentence imposed by the United States District Court for the District of Alaska for possessing controlled substances with intent to distribute them. A loaded handgun was found inside the pocket of her jacket during a search of her car. Her presentence report recommended, and the sentencing court applied, a two-level sentencing enhancement for possessing a dangerous weapon during the offense.
After completing RDAP, Henry learned that the firearm enhancement made her ineligible for the possible sentence reduction of up to one year. She asked the Alaska district court to clarify that she was a nonviolent offender eligible for the reduction, but that court denied her motion. She then appealed the Bureau’s decision through the Bureau’s administrative process. The Administrator of National Inmate Appeals denied the appeal on October 21, 2019. The opinion states that this exhausted Henry’s administrative remedies.
Respondent’s motion
The respondent moved to dismiss the petition for lack of subject-matter jurisdiction, meaning the court’s legal power to decide the claim. Henry did not file an opposition before the deadline.
Court’s analysis
The court explained that federal law allows the Bureau of Prisons to provide residential substance-abuse treatment and permits the Bureau to reduce an eligible prisoner’s custody term by up to one year. The regulations exclude prisoners whose current felony conviction involved carrying, possessing, or using a firearm.
The court relied on Reeb v. Thomas, in which the Ninth Circuit held that a district court cannot review the Bureau’s substantive decision about whether a particular inmate should receive an RDAP-related sentence reduction. The court noted that judicial review remains available for claims that Bureau action violates federal law or the Constitution, or exceeds the Bureau’s statutory authority. But review is unavailable when the claim argues that the Bureau made an error based on the particular facts of the inmate’s case.
Henry argued that the Bureau incorrectly relied on the fact that a gun was found in her car instead of considering that she committed a nonviolent crime. The court characterized this as a challenge based on the specific facts of Henry’s case and held that it therefore lacked jurisdiction.
Disposition
The court granted the motion to dismiss based on lack of jurisdiction. Because amendment would be futile, the court dismissed the case with prejudice. The clerk was ordered to enter a separate judgment and close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.