Stephenson v. Segal

Background

Elizabeth Marie Stephenson filed a habeas petition against Michael Segal, identified in the caption as warden. Her petition argued that the Federal Bureau of Prisons (BOP) miscalculated her time credits under the First Step Act of 2018. She contended that she was entitled to at least 10 days of credit for each individual evidence-based recidivism-reduction program in which she was simultaneously enrolled. The opinion states that she was enrolled in 19 such courses at once around the time she filed the petition.

A magistrate judge recommended denying the habeas petition. The recommendation concluded that 18 U.S.C. § 3632(d)(4)(A) provides credits for every 30 days of successful participation in qualifying programming, not separate credits for every program completed.

Stephenson later submitted an addendum. She claimed that her case manager was withholding First Step Act credits because she was not making required restitution payments. She asserted that she could not make those payments because she had no income and that the BOP could not withhold credits for that reason. The magistrate judge recommended dismissing this claim without prejudice because Stephenson had not exhausted her administrative remedies.

Court’s Analysis

The district court reviewed the portions of the recommendations to which Stephenson specifically objected. It agreed with the magistrate judge’s statutory interpretation, concluding that the text of the First Step Act did not support awarding credits for each program in which a prisoner participated simultaneously. Because the statute’s text plainly did not support Stephenson’s interpretation, the court found it unnecessary to analyze whether the BOP’s interpretation was entitled to deference under the Chevron doctrine.

The court found no error in the conclusion that the addendum claim had not been exhausted. Although it was not entirely clear whether Stephenson objected to that conclusion, the court reviewed the entire record and noted that she had learned of the claim shortly before submitting the addendum. The court stated that, if the required administrative remedies were unsuccessful, Stephenson could file a new habeas action raising the argument in the future.

The court also addressed Stephenson’s concerns about conditions at the Federal Correctional Institution in Waseca. It stated that, under Eighth Circuit law, conditions-of-confinement claims are not appropriately decided in a habeas proceeding.

Disposition

Judge Katherine Menendez accepted the May 5 and May 15 reports and recommendations and overruled Stephenson’s objections. The court denied the habeas petition and dismissed the claim raised in the addendum without prejudice for failure to exhaust administrative remedies. The order directed that judgment be entered accordingly.