Keahbone v. Segal
- Wilhelmina Wright
- 0:23-cv-00750
- U.S. District Court · District of Minnesota
- 4
In Keahbone v. Segal, Judge Wright denied Keahbone’s request for additional First Step Act sentence credits and dismissed the case.
Jamie L. Keahbone’s request for additional First Step Act time credits was denied; the BOP’s calculation method was upheld.
What happened
In Keahbone v. Segal, Jamie L. Keahbone challenged how the Bureau of Prisons calculated her First Step Act time credits. She argued that participating in multiple programs at the same time entitled her to credits for each program.
The court agreed with the Bureau of Prisons that credits are based on the days spent in eligible programming during a 30-day period, not on the number of programs attended. The court also declined to consider new conditions-of-confinement claims raised only in her objections.
Judge Wright overruled Keahbone’s objections, adopted the magistrate judge’s recommendation, denied her petition, and dismissed the matter.
The detailed version
- Keahbone v. Segal · No. 0:23-cv-00750
- Wilhelmina Wright
- Oct. 30, 2023
Background
Jamie L. Keahbone filed a habeas petition, meaning a request for judicial relief from allegedly improper custody or sentence administration. She argued that the Bureau of Prisons (BOP) incorrectly calculated her time credits under the First Step Act of 2018.
The First Step Act allows eligible prisoners to earn time credits for successful participation in evidence-based recidivism-reduction programs or productive activities. The statute provides 10 days of credit for every 30 days of successful participation, with an additional 5 days for certain prisoners who remain at minimum or low risk of recidivating over two consecutive assessments.
Keahbone argued that a prisoner enrolled in 10 eligible programs at the same time could earn 10 or 15 days of credit for each program during a month, for as many as 150 credits. The BOP interpreted the law to award credits based on the days spent in eligible programming, rather than the number of programs attended.
Report and Recommendation and Objections
A magistrate judge recommended denying the petition. Keahbone filed objections. Because the objections repeated arguments from her petition, the district court reviewed them for clear error. The court also stated that it liberally interpreted her filings because she represented herself.
Court’s Analysis
The court concluded that the BOP’s interpretation was correct: prisoners earn First Step Act credits based on the number of days spent in eligible programming during a 30-day period, not on the number of eligible programs attended during that period. The court noted that the courts cited in the opinion had agreed with the BOP’s interpretation.
The court also held that new arguments raised in the objections, including several conditions-of-confinement claims, had been waived because they were not raised in the original petition and were not properly included in this type of petition.
Disposition
The court overruled Keahbone’s objections, adopted the May 5, 2023 Report and Recommendation, denied her habeas petition, and dismissed the matter. The order directed that judgment be entered accordingly.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.