Chicoine v. Segal

Background

Courtney M. Chicoine filed a petition challenging the Bureau of Prisons’ calculation of her time credits under the First Step Act of 2018. She argued that she should receive 15 days of credit for each of the 30 individual programs in which she was simultaneously enrolled each month. Under that theory, she would receive 450 days of credit per month.

United States Magistrate Judge Tony N. Leung recommended denying the petition and dismissing the action. He concluded that 18 U.S.C. § 3632(d)(4)(A) awards credits for every 30 days of successful participation in eligible programming, rather than 15 days for every program completed. The opinion also notes that Chicoine’s request for compassionate release could be granted only by the district court that sentenced her.

Objections and Analysis

Chicoine objected to the recommendation. The court reviewed the challenged portions of the recommendation independently, as required when a party makes specific objections. The court agreed with Judge Leung that the statutory text plainly did not support Chicoine’s interpretation. Because the court found the statute unambiguous, it said there was no need to analyze whether the Bureau of Prisons’ interpretation deserved deference under the doctrine associated with Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.

Chicoine also raised concerns about conditions at the Federal Correctional Institution in Waseca. The court stated that, under Eighth Circuit law, those claims are not appropriately decided through a habeas proceeding, which is a petition challenging the legality or duration of custody rather than prison conditions.

Disposition

Judge Katherine Menendez accepted the May 30, 2023 Report and Recommendation, overruled Chicoine’s objections, denied the habeas petition, and dismissed the action. The court directed that judgment be entered. The opinion does not state that the dismissal was with or without prejudice.