Stamps v. Segal
- Wilhelmina Wright
- 0:23-cv-01076
- U.S. District Court · District of Minnesota
- 4
In Stamps v. Segal, Judge Wright denied Stamps’s challenge to First Step Act credits, overruling her objection and adopting the recommendation.
Alessandra Katie Stamps was denied First Step Act time credits and her habeas petition and motion were denied; the matter was dismissed without prejudice. Michael Segal, identified as the warden, was the respondent.
What happened
In Stamps v. Segal, Alessandra Katie Stamps sought sentence-reduction credits under the First Step Act. She argued that the sentencing court wrongly found she was an organizer, leader, manager, or supervisor because she was the only person named in her indictment.
The court rejected that argument, finding that three other people were listed in the indictment to which Stamps pleaded guilty. Because the law excludes people convicted of certain serious drug offenses who were found to have that leadership role, the court concluded that Stamps could not receive the credits.
Judge Wright overruled Stamps’s objection, adopted the magistrate judge’s recommendation, denied both her petition and her motion for a writ of habeas corpus, and dismissed the matter without prejudice.
The detailed version
- Stamps v. Segal · No. 0:23-cv-01076
- Wilhelmina Wright
- Oct. 24, 2023
Background
The First Step Act provides time credits to prisoners who successfully complete qualifying recidivism-reduction programs or productive activities. The statute excludes people convicted of certain serious drug offenses under 21 U.S.C. § 841(b) who were found at sentencing to be an organizer, leader, manager, or supervisor of others in the offense.
Stamps filed a petition seeking those credits. She argued that the sentencing court could not properly find that she had a leadership role because she was the only person listed in her indictment. A magistrate judge recommended denying the petition. Stamps objected to that recommendation.
Analysis
The district court explained that it reviews the objected-to portions of a magistrate judge’s report and recommendation de novo, but reviews objections that merely repeat arguments already presented to the magistrate judge for clear error. Because Stamps repeated the arguments from her petition, the court applied clear-error review. The court also stated that it would not consider new evidence that had not been presented to the magistrate judge.
The court rejected Stamps’s factual argument. It agreed with the report and recommendation that three other individuals were listed in the indictment to which Stamps pleaded guilty. The court therefore concluded that Stamps was ineligible for First Step Act time credits.
Disposition
The court overruled Stamps’s objection, adopted the report and recommendation, denied her petition for a writ of habeas corpus, denied her separate motion for a writ of habeas corpus, and dismissed the matter without prejudice. Judgment was ordered to be entered accordingly.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.