Matthews v. Sagal
- Paul Magnuson
- 0:23-cv-01030
- U.S. District Court · District of Minnesota
- 3
In Matthews v. Sagal, Judge Magnuson denied Matthews’s habeas petition, ruling that programming credits accrue monthly, not per class.
Dannielle A. Matthews and federal prisoners whose programming time-credit claims depend on whether credits are calculated per month or per class.
What happened
Matthews v. Sagal concerned Dannielle A. Matthews’s challenge to the Bureau of Prisons’ calculation of time credits for programming she completed in prison. She argued that credits should be awarded for each class rather than for each month of programming.
The court agreed with the magistrate judge that prisoners receive 10 or 15 days of credit per month of qualifying programming, not per class. The court also said the Bureau of Prisons’ interpretation was reasonable and therefore entitled to deference. Matthews’s separate objection about facility understaffing was not considered because she had not raised it in her petition and had not identified specific personal harm.
Judge Magnuson adopted the report and recommendation, denied Matthews’s habeas petition, and dismissed the matter. The order entered judgment accordingly.
The detailed version
- Matthews v. Sagal · No. 0:23-cv-01030
- Paul Magnuson
- May 23, 2023
Background
Dannielle A. Matthews petitioned for habeas relief, asking the court to review the Bureau of Prisons’ calculation of time credits that she earned by participating in programming at her institution. The petition argued that the credits should be calculated for each class in which she participated. The matter came before the court on Magistrate Judge Elizabeth Cowan Wright’s Report and Recommendation, which recommended denying the petition and dismissing the case. Matthews timely objected.
Court’s Analysis
The court reviewed de novo the portions of the recommendation to which Matthews specifically objected. It agreed with the recommendation that the Bureau of Prisons interprets the governing statute to provide 10 or 15 days of credit per month of qualifying programming, rather than 10 or 15 days for each class. The court noted that other courts addressing the issue had agreed with that interpretation and that Matthews’s proposed reading could produce what the court described as absurd results.
The court further held that, even if the Bureau of Prisons’ interpretation were not the best reading of the statute, it was reasonable. Under the precedent cited by the court, the court was required to defer to that reasonable agency interpretation. The court rejected Matthews’s argument that the Supreme Court might soon change that precedent, explaining that the court was bound by existing Supreme Court rulings rather than speculation about future decisions.
Matthews also objected that staffing problems had reduced the number of classes offered at the facility. The court stated that she had not claimed she was unable to take classes she wanted or identified the personal harm she suffered from understaffing. It also held that the issue was not properly considered because Matthews had not raised it in her petition.
Disposition
The court adopted the Report and Recommendation, denied the Petition for a Writ of Habeas Corpus, and dismissed the matter. The order did not add a prejudice designation to the dismissal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.