Rojas v. Segal
- Paul Magnuson
- 0:23-cv-01306
- U.S. District Court · District of Minnesota
- 2
In Rojas v. Segal, Judge Magnuson denied habeas relief, ruling that First Step Act credits accrue monthly rather than per course.
Shannon L. Rojas; the ruling concerns how the Bureau of Prisons awards First Step Act time credits to federal prisoners participating in programming.
What happened
In Rojas v. Segal, Shannon Rojas challenged the Bureau of Prisons’ calculation of time credits under the First Step Act of 2018 for participating in programming. She argued that prisoners should receive 10 or 15 days of credit for each completed course.
The court rejected that interpretation. It held that prisoners receive the credit for each month of programming in which they participate, not for every course they complete. The court also said the Bureau of Prisons’ interpretation was reasonable and therefore deserved deference even if the court might have interpreted the law differently.
Judge Magnuson ruled that Rojas was not entitled to habeas relief. He denied the petition and dismissed the matter, ordering that judgment be entered.
The detailed version
- Rojas v. Segal · No. 0:23-cv-01306
- Paul Magnuson
- May 16, 2023
Background
Shannon L. Rojas, identified as the petitioner, filed a petition for a writ of habeas corpus against Michael Segal, Warden. The petition challenged how the Bureau of Prisons awards time credits under the First Step Act of 2018 for participation in certain programming. The court reviewed the petition under Rule 4 of the Rules Governing Section 2254 Cases, while noting that the petition was not brought under 28 U.S.C. § 2254 and that those rules could nevertheless be applied under Rule 1(b).
The opinion stated that many prisoners at the Federal Correctional Institution in Waseca, Minnesota, had filed similar petitions. Rojas’s position was that prisoners should receive 10 or 15 days of credit for each course they complete.
Court’s analysis
The court rejected Rojas’s interpretation. It agreed with the Bureau of Prisons that the credits are awarded for each month of programming in which a prisoner participates, rather than for each completed course. The court also found that this interpretation was reasonable. Citing precedent requiring deference to a reasonable agency interpretation, the court concluded that Rojas was not entitled to habeas-corpus relief.
Disposition
The court ordered that the petition for a writ of habeas corpus was DENIED and that the matter was DISMISSED. The order did not state that the dismissal was with or without prejudice. Judge Paul A. Magnuson signed the order on May 16, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.