Valdez-Garcia v. Segal

Background

Lisa Nicole Valdez-Garcia, appearing without a lawyer, petitioned for a writ of habeas corpus, a court proceeding seeking relief from allegedly unlawful custody or the calculation of the time remaining in custody. The petition concerned time credits under the First Step Act of 2018. The statute generally allows an eligible prisoner to earn 10 days of time credits for every 30 days of successful participation in qualifying recidivism-reduction programming or productive activities.

Magistrate Judge David T. Schultz recommended denying the petition. Valdez-Garcia objected. The district court reviewed the objection and the recommendation independently, as required when a party objects to a magistrate judge’s report and recommendation.

Legal Issue

Valdez-Garcia argued that participating in multiple qualifying programs on the same day entitled her to credit for multiple days of programming. The opinion gives the example that participating in three one-hour programs on one day should count as three days of programming.

Court’s Reasoning

The court held that this interpretation was plainly wrong. Section 3632(d)(4)(A) bases time credits on the number of days spent in programming, not the number of programs. Thus, participating in one program on a particular day counts as one day, and participating in five programs on that same day also counts as one day. Because the statute was clear and the Bureau of Prisons’ interpretation matched the statute’s meaning, the court did not decide how much judicial deference the Bureau’s interpretation might receive under the cited precedent.

Disposition

The court overruled Valdez-Garcia’s objection, adopted Judge Schultz’s report and recommendation, and denied Valdez-Garcia’s petition for a writ of habeas corpus. The order also directed that judgment be entered accordingly.