Ward v. Federal Bureau of Prisons
- Katherine Menendez
- 0:24-cv-00571
- U.S. District Court · District of Minnesota
- 2
In Ward v. Federal Bureau of Prisons, Judge Menendez denied Ward’s petition, dismissed the action without prejudice, and denied a stay for failure to exhaust.
Madison Ward’s sentence-credit challenge was dismissed without prejudice, and her request to pause the case was denied. The Bureau of Prisons was the respondent.
What happened
Ward v. Federal Bureau of Prisons involved Madison Ward’s challenge to the Bureau of Prisons’ alleged failure to apply time credits properly to her sentence. Ward, who was incarcerated at the Federal Correctional Institution in Waseca, Minnesota, filed the case under a federal law allowing prisoners to challenge unlawful custody or sentence calculations.
Magistrate Judge David T. Schultz concluded that Ward had not completed the Bureau of Prisons’ administrative process before filing her petition. He recommended dismissing the case without prejudice and denying Ward’s request to pause the case while she completed that process. Ward did not object to the recommendation by the deadline.
Judge Katherine Menendez reviewed the recommendation for clear error, found none, and accepted it. The court denied Ward’s petition, dismissed the action without prejudice for failure to exhaust administrative remedies, and denied her request to stay or continue the case; the opinion states that she may file a new action after exhausting those remedies.
The detailed version
- Ward v. Federal Bureau of Prisons · No. 0:24-cv-00571
- Katherine Menendez
- June 14, 2024
Background
Madison Ward, identified as the petitioner, filed this case under 28 U.S.C. § 2241, a federal law that allows a person in custody to challenge the execution or calculation of a sentence. Ward alleged that the United States Bureau of Prisons had not properly applied time credits to her sentence. The opinion states that she was incarcerated at the Federal Correctional Institution in Waseca, Minnesota.
On March 19, 2024, United States Magistrate Judge David T. Schultz ordered Ward to explain whether she had exhausted administrative remedies concerning her claim. Ward stated that she had submitted materials to the Bureau of Prisons in an effort to resolve the issue. Judge Schultz construed that response as a concession that she had not exhausted the administrative process before filing the petition.
Report and Recommendation
Judge Schultz issued a Report and Recommendation on April 23, 2024. He recommended dismissing the action without prejudice because Ward had not exhausted her administrative remedies. A dismissal without prejudice does not bar a new action based on the same matter. The recommendation also advised denying Ward’s request to stay or continue the case until she completed the administrative process. The opinion states that Ward could file a new action after exhausting her administrative remedies if she remained dissatisfied with the Bureau of Prisons’ outcome.
Ward did not object to the Report and Recommendation by the May 7, 2024 deadline. Because there were no objections, Judge Menendez reviewed the recommendation for clear error, meaning an obvious mistake in the recommendation. She found no clear error and accepted the recommendation.
Ruling
The court ordered four things:
- The Report and Recommendation was accepted.
- Ward’s petition for a writ of habeas corpus was denied.
- The action was dismissed without prejudice based on Ward’s failure to exhaust administrative remedies.
- Ward’s request to stay or continue the action while she pursued administrative remedies was denied.
The order directed that judgment be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.