Davis v. Rardin

Background

William Scott Davis, Jr., a federal prisoner incarcerated at the Federal Medical Center in Rochester, Minnesota, filed a petition under 28 U.S.C. § 2241, the federal procedure generally used to challenge how a sentence is being carried out. His amended petition listed 50 grounds, although the court found that some were duplicative and others combined multiple theories.

Davis was serving a 144-month sentence after a jury convicted him of one count of cyberstalking and three counts of sending threatening communications. The opinion states that his statutory release date was May 12, 2025, and that First Step Act credits moved his projected release date to May 12, 2024.

Claims involving the conviction and sentence

The court concluded that Davis’s attacks on his conviction and sentence could not be brought through a § 2241 petition. Those challenges generally must be presented to the court that imposed the sentence through a motion under 28 U.S.C. § 2255. Davis had already sought that relief in the sentencing court and did not show an exceptional circumstance that would allow him to proceed under § 2241.

The court therefore recommended denying both the amended habeas petition to the extent it challenged the conviction or sentence and Davis’s separate § 2255 motion filed in this case.

Prison placement and compassionate release

The court determined that Davis’s requests for transfer to a halfway house or home confinement challenged the place of confinement, rather than the fact or duration of confinement. It concluded that such placement decisions generally cannot be reviewed through a habeas petition. It also found that, even if the claims were reviewable, the Bureau of Prisons had conducted the required individualized assessment, determined that Davis’s medical needs could not be accommodated by a halfway house, and found that he lacked a suitable address for home confinement.

The court separately concluded that requests for compassionate release under 18 U.S.C. § 3582(c)(1)(A) had to be brought in the court that imposed Davis’s sentence, not in this District of Minnesota case.

Sentence and First Step Act credit calculations

The court rejected Davis’s challenge to the Bureau of Prisons’ calculation of his sentence. The record showed that he spent 1,247 days in federal custody before sentencing and received 1,247 days of credit toward his sentence. The court found no available habeas relief based on a calculation error.

The court also found that Davis had already received the maximum 365 days of First Step Act credits that could be used for early release. It rejected any claim that additional credits could shorten his term of supervised release, concluding that the statute permits credits to move supervised release closer in time but does not reduce the length of supervised release.

Residential Drug Abuse Program

The court rejected Davis’s challenge to his exclusion from the Bureau of Prisons’ Residential Drug Abuse Program. Although Davis argued that the Bureau improperly treated a prior assault conviction as a disqualifying violent offense, the court found that he was independently ineligible because he had not provided evidence of a substance-abuse problem, which the program requires. The court therefore did not need to decide whether the Bureau correctly characterized his prior criminal history.

Disciplinary proceedings

Davis challenged four prison disciplinary proceedings that resulted in the loss of good-conduct time. The court reviewed due-process requirements, including notice of the charges, an opportunity to present evidence subject to prison-safety limits, and a written decision supported by at least some evidence.

The court found that each proceeding provided timely notice, one or more hearings, an opportunity to present evidence, and a written explanation supported by evidence. It found that delays in receiving some written disciplinary decisions violated Bureau policy but did not establish a due-process violation because Davis identified no prejudice. The court also concluded that officials did not violate the Constitution by removing Davis from two hearings after disruptive conduct or by proceeding without earlier competency examinations.

Financial claims and other allegations

Davis alleged that the Bureau of Prisons improperly handled two Treasury checks deposited into his inmate trust account and that this affected his financial obligations and First Step Act credits. The court stated that the Bureau appeared to have disregarded its own policy and Davis’s choice not to authorize the Bureau to endorse checks for him. However, it concluded that these allegations did not concern the legality or length of his detention and therefore could not support habeas relief. It also noted that Davis had already reached the statutory limit on credits usable for early release.

The court further concluded that Davis’s allegations concerning administrative remedies, legal supplies, retaliation, prison care, and community confinement generally were not claims that could be remedied through habeas proceedings. It found no basis for his requests for declaratory or injunctive relief.

Other motions and disposition

The court ordered the following:

- Davis’s motion for sanctions was denied. - Davis’s motion for appointment of counsel was denied. - Davis’s motion for production was denied. - Davis’s other discovery motion was denied. - Davis’s request for copies of court filings was granted in part and denied in part. The clerk was directed to mail him the docket for this case, while any request for the docket in his criminal case was left for the original sentencing court.

The court also found that no evidentiary hearing was necessary because the record disclosed no material factual dispute.

The Report and Recommendation recommended that Davis’s amended petition be denied, his separate § 2255 motion be denied, and his motion for a temporary restraining order and preliminary injunction be denied. The opinion states that the Report and Recommendation was not itself a final order or judgment and was not directly appealable to the Eighth Circuit. Parties could file written objections within the period stated in the notice.