Friday v. Segal

Background

Cleone Cecelia Friday filed a petition for a writ of habeas corpus, a court petition challenging the legality or administration of a person’s imprisonment. She disputed the Bureau of Prisons’ calculation of time credits earned through programming at her institution. The magistrate judge recommended that the petition be denied and the matter dismissed. Friday timely objected.

Issue and analysis

The court reviewed de novo—the required fresh review of the parts of a magistrate judge’s recommendation that a party specifically challenges—the recommendation concerning Friday’s objection. Friday argued that the governing statute entitled her to 10 or 15 days of credit for each class in which she participated. The court rejected that interpretation, explaining that courts had agreed with the Bureau of Prisons that prisoners receive 10 or 15 days of credit per month of programming participation, not per class.

The court also stated that, even if the Bureau of Prisons’ interpretation were incorrect, it was reasonable. The court therefore concluded that established precedent required deference to that interpretation and that Friday was not entitled to relief.

Disposition

The court adopted the Report and Recommendation, denied Friday’s petition, and dismissed the matter. The order did not state that the dismissal was with or without prejudice. Judge Paul A. Magnuson directed that judgment be entered accordingly.