Estabrook v. Segal

Background

Alicia K. Estabrook filed a petition for a writ of habeas corpus, a legal procedure for challenging unlawful custody or the way a sentence is being carried out. The petition concerned the measurement of prisoners’ time credits based on participation in eligible programs. United States Magistrate Judge John F. Docherty issued a Report and Recommendation dated May 9, 2023, recommending that the petition be denied and the action dismissed. Estabrook, who represented herself, objected.

Court’s analysis

The district court reviewed the parts of the recommendation to which Estabrook objected without deference and reviewed the unobjected portions for clear error. Estabrook challenged the recommendation’s alternative conclusion that the relevant regulation was a reasonable interpretation of the statute. She did not challenge the recommendation’s primary conclusion that the statute’s plain language unambiguously requires measuring time credits according to the number of days prisoners participate in eligible programs. The court found no clear error in that primary analysis and therefore found Estabrook’s objection to the alternative analysis inconsequential.

The court also addressed issues Estabrook raised for the first time in her objection. It stated that those issues concerned conditions of confinement, which are not claims that can be considered in a habeas proceeding. The court further held that Estabrook waived those issues by failing to raise them in her original petition.

Disposition

The court overruled Estabrook’s objection and accepted the Report and Recommendation in its entirety. It denied Estabrook’s petition and dismissed the action. The order did not state whether the dismissal was with or without prejudice.