Maccord v. United States

Background

Donald Maccord filed a petition under 28 U.S.C. § 2241, a law that allows a person in federal custody or under federal supervision to challenge the way the sentence is being carried out. He argued that he had been improperly deprived of time credits under the First Step Act.

Maccord was sentenced in the Northern District of California, served approximately 20 months in a federal penitentiary in Montgomery, Alabama, and was on supervised release in the Southern District of California. The opinion also states that he initially sent the petition to the Central District of California, that the clerk's office mailed it to the Southern District of California, and that it was then inadvertently mailed to the Northern District of California.

Reasoning

The court explained that federal courts generally consider the district where a petitioner is confined to be the most convenient forum for a petition of this kind. It relied on that principle and on the authority to transfer a case when doing so serves the interests of justice. Because Maccord was on supervised release in the Southern District of California, the court treated that district as his district of confinement.

Order and effect

Judge Susan Van Keulen ordered that the case be transferred to the Southern District of California. The clerk was directed to terminate all pending motions and transfer the entire file. The order did not decide whether Maccord was entitled to the claimed First Step Act time credits.