Melendez-Vega v. United States

Background

Alissa M. Melendez-Vega filed a habeas petition challenging the Federal Bureau of Prisons’ calculation of her time credits under the First Step Act of 2018. She argued that she was entitled to at least 10, or as many as 15, days of credit for each individual eligible program in which she participated simultaneously each month.

United States Magistrate Judge David T. Schultz 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 qualifying programming, not for each separate program completed. Melendez-Vega objected to that recommendation and also raised concerns about conditions at the Federal Correctional Institution in Waseca.

Analysis

The district court reviewed the portions of the recommendation to which Melendez-Vega specifically objected without deference, as required by 28 U.S.C. § 636(b)(1) and the District of Minnesota’s local rules. The court agreed with Magistrate Judge Schultz’s statutory analysis and stated that the First Step Act’s text plainly and unambiguously did not support Melendez-Vega’s interpretation.

Melendez-Vega also criticized the Chevron doctrine, under which courts may defer to an agency’s interpretation of an ambiguous statute that the agency administers. The court determined that it did not need to consider that doctrine because the statute was unambiguous. The court further held that Melendez-Vega’s conditions-of-confinement concerns were not appropriately adjudicated through a habeas proceeding under Eighth Circuit precedent.

Disposition

The court accepted the May 9, 2023 Report and Recommendation, overruled Melendez-Vega’s objections, denied the habeas petition, and dismissed the action. The order did not state that the dismissal was with or without prejudice.