Williams v. Marques
- John Tunheim
- 0:18-cv-03055
- U.S. District Court · District of Minnesota
- 6
In Williams v. Marques, Judge Tunheim rejected Williams’s challenge to a regulation limiting sentence reductions for certain federal firearm offenders.
The ruling directly affected Jay Michael Williams. It also upheld the Bureau of Prisons’ regulation limiting sentence reductions for prisoners convicted of nonviolent offenses involving firearms.
What happened
In Jay Michael Williams v. R. Marques, Williams, who was serving a federal sentence in Minnesota, challenged a regulation that bars people convicted of nonviolent firearm offenses from receiving certain sentence reductions after completing a substance-abuse treatment program. He argued that the regulation was unreasonable and conflicted with a 2018 federal law.
Williams argued that data showing lower reoffending rates after treatment undermined the Bureau of Prisons’ public-safety rationale. He also argued that the 2018 law required eligible prisoners, including nonviolent firearm offenders, to receive early-release credits.
Judge John R. Tunheim overruled Williams’s objections, adopted the magistrate judge’s recommendation, and declined to grant a certificate of appealability. The court concluded that the regulation was reasonable and that the 2018 law did not require sentence-reduction credits under the earlier program.
The detailed version
- Williams v. Marques · No. 0:18-cv-03055
- John Tunheim
- Feb. 5, 2019
Background
Williams filed a petition under 28 U.S.C. § 2241, a procedure prisoners may use to challenge the legality of their custody or the execution of their sentence. He challenged 28 C.F.R. § 550.55, which makes federal prisoners convicted of nonviolent offenses involving firearms ineligible for a sentence reduction under 18 U.S.C. § 3621(e)(2)(B), even if they successfully complete the Bureau of Prisons’ Residential Drug Abuse Program.
Williams claimed that the regulation was arbitrary and capricious under § 706 of the Administrative Procedure Act. A magistrate judge recommended denying the petition based on precedent upholding the regulation. Williams filed objections.
Analysis
The court rejected Williams’s argument that later evidence of reduced reoffending rates among people who completed the treatment program invalidated the regulation. The court explained that the question was whether the regulation was a permissible interpretation of the governing statute, not whether another policy might be more reasonable. The court followed binding precedent holding that the Bureau of Prisons could categorically deny discretionary sentence-reduction benefits to certain nonviolent offenders and that its public-safety concerns about nonviolent firearm offenders were reasonable.
The court also rejected Williams’s argument based on the First Step Act of 2018. The court held that the Act did not designate the Residential Drug Abuse Program, or any other particular program, as one that must provide sentence-reduction credits under the Act. It also held that the Act did not amend § 3621 or require sentence-reduction incentives for nonviolent firearm offenders. In addition, the court noted that the Act expressly barred awarding credits for qualifying programs completed before the Act’s enactment.
Disposition
The court overruled Williams’s objections and adopted the magistrate judge’s Report and Recommendation. The court therefore denied the requested relief. It also declined to grant a certificate of appealability, finding that Williams had not shown that reasonable judges could debate the issues or resolve them differently. The order stated that judgment should be entered accordingly.
Note on the opinion
One sentence in the background refers to Williams as the “Defendant,” although the caption identifies him as the plaintiff and the opinion otherwise treats him as the petitioner. This summary follows the caption and the court’s substantive discussion.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.