Garcia v. Segal

Background

Celina Alexandra Garcia, who represented herself, filed a petition asking the court to review her custody through a legal process called habeas corpus. She was incarcerated at FCI Waseca after pleading guilty to conspiracy to distribute methamphetamine. Garcia alleged that the Bureau of Prisons improperly calculated and failed to apply 530 days of earned time credit under the First Step Act of 2018.

Garcia argued that her participation in qualifying evidence-based recidivism-reduction programs and productive activities entitled her to 10 days of credit for every 30-day period in each program, including programs taken at the same time. The magistrate judge recommended denying and dismissing the petition. Garcia objected, arguing that the Bureau of Prisons had not properly applied the Act.

Court’s analysis

The court reviewed the portions of the magistrate judge’s recommendation to which Garcia objected. It held that Garcia’s interpretation of the First Step Act was incorrect. Under 18 U.S.C. § 3632(d)(4)(A)(i), a prisoner earns 10 days of credit for every 30 days of successful participation in qualifying programming or productive activities. The court read that provision as measuring participation by the number of days, not by the number of programs or classes completed.

The court therefore held that participating in one program or many programs simultaneously does not create additional credit for each program. It also concluded that the Bureau of Prisons’ regulation, which provides 10 days of credit for each 30-day period of qualifying participation regardless of the number of programs, supported that interpretation. The court said the statutory language was unambiguous. Alternatively, it found that the Bureau of Prisons’ interpretation would be reasonable even if the statute were ambiguous.

The court also addressed additional arguments Garcia raised in her objection. It stated that many concerned conditions of confinement, which are not proper claims in a habeas petition when the prisoner is not challenging the validity of the conviction or the length of detention. The court further stated that the new arguments had not been presented to the magistrate judge and therefore were waived.

Disposition

The court overruled Garcia’s objection, adopted the magistrate judge’s Report and Recommendation, denied Garcia’s habeas petition, and dismissed her action without prejudice. The order explained that dismissal without prejudice reserved Garcia’s right to sue again and allowed her to refile or alter her claim if new information relevant to the court’s decision became available. Judge John R. Tunheim signed the order.