Robinson v. Segal
- Wilhelmina Wright
- 0:23-cv-00888
- U.S. District Court · District of Minnesota
- 4
In Robinson v. Segal, Judge Wright denied Robinson’s petition challenging imprisonment, ruling First Step Act credits depend on eligible-program days, not number of programs.
Ashlei Renee Robinson’s request for additional First Step Act time credits was denied; the Bureau of Prisons’ method of calculating her credits was upheld in this case.
What happened
Robinson v. Segal concerned Ashlei Renee Robinson’s challenge to how the Bureau of Prisons calculated her time credits under the First Step Act. She argued that credits should be based on the number of eligible programs she completed, rather than the number of days she participated.
The court agreed with the Bureau of Prisons that the credits are calculated from days spent in eligible programming during a 30-day period. It also declined to consider new claims and arguments that Robinson raised only in her objections to the magistrate judge’s recommendation.
Judge Wilhelmina M. Wright overruled Robinson’s objections, adopted the magistrate judge’s recommendation, and denied her petition asking the court to review her imprisonment.
The detailed version
- Robinson v. Segal · No. 0:23-cv-00888
- Wilhelmina Wright
- June 27, 2023
Background
Ashlei Renee Robinson filed a petition for a writ of habeas corpus, meaning a request for court review of the legality of her imprisonment. She alleged that the Bureau of Prisons incorrectly calculated the time credits she earned under the First Step Act of 2018.
The Act provides time credits to prisoners who successfully participate in evidence-based programs or productive activities. It provides 10 days of credit for every 30 days of successful participation, plus an additional 5 days for certain prisoners whom the Bureau of Prisons determines have a minimum or low risk of reoffending and whose risk has not increased over two consecutive assessments.
Robinson argued that the credits should be awarded based on the number of eligible programs completed. Under her interpretation, participating in 10 programs could produce 10 or 15 days of credit per month for each program, up to 150 credits. The Bureau of Prisons interprets the law as awarding credits based on the number of days spent in eligible programming, not the number of programs attended. Robinson asked the court to order the Bureau of Prisons to award her substantially more credits.
Review of the Recommendation
United States Magistrate Judge David T. Schultz recommended denying the petition. Robinson filed objections. Because the objections repeated arguments made in her petition, the district court reviewed them for clear error, rather than conducting a fresh review of those issues. The court also stated that it would not consider new evidence or new claims and arguments that Robinson had not presented to the magistrate judge.
Merits
The court agreed with the magistrate judge and the Bureau of Prisons’ interpretation. It stated that every court that had considered the issue agreed that First Step Act credits are based on the number of days spent in eligible programming during a 30-day period, not the number of eligible programs attended during that period. Because Robinson was not entitled to the additional relief she requested, the court denied her petition.
Disposition
The court overruled Robinson’s objections, adopted the May 5, 2023 Report and Recommendation, and denied Robinson’s petition for a writ of habeas corpus. The order did not add a prejudice qualifier to the denial.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.