Ranglin v. Warden
- Laura Swain
- 1:22-cv-07642
- U.S. District Court · Southern District of New York
- 2
In Ranglin v. Warden, Judge Swain transferred the sentence-credit petition to Indiana and denied fee-free status for an appeal.
Matthew Ranglin, the incarcerated petitioner challenging the Bureau of Prisons’ subtraction of 89 days of sentence credit; the case was transferred to the federal court for the Southern District of Indiana.
What happened
Matthew Ranglin, who was incarcerated at a federal prison in Indiana, filed a self-represented submission challenging the Bureau of Prisons’ subtraction of 89 days of credit toward completion of his sentence. The court treated it as a petition challenging how his sentence was being carried out.
The court explained that this type of petition generally must be considered where the prisoner is confined because that court has authority over the prisoner’s custodian. Because Ranglin was confined in Terre Haute, Indiana, the court transferred the case to the federal court for the Southern District of Indiana.
Judge Swain directed the clerk to transfer the case and said the Indiana court would decide whether Ranglin could proceed without paying fees or without an original signature. The order closed the case in the Southern District of New York and denied fee-free status for any appeal, after certifying that an appeal would not be taken in good faith.
The detailed version
- Ranglin v. Warden · No. 1:22-cv-07642
- Laura Swain
- Sept. 9, 2022
Background
Matthew Ranglin filed a self-represented submission challenging the Federal Bureau of Prisons’ subtraction of 89 days of credit toward completion of his sentence. Ranglin was incarcerated at the Federal Correctional Institution in Terre Haute, Indiana. The court treated the submission as a petition under 28 U.S.C. § 2241, a procedure for challenging the execution—meaning the carrying out—of a federal sentence.
Transfer Decision
The court explained that a court considering a § 2241 petition must have authority over the prisoner’s custodian. It stated that jurisdiction generally lies in the federal district where the prisoner is confined. Because Ranglin was confined at the Terre Haute facility, which is in the Southern District of Indiana, the court transferred the action there under 28 U.S.C. § 1406(a), in the interest of justice.
Disposition
The court directed the clerk to transfer the action to the United States District Court for the Southern District of Indiana. It left to the transferee court the decisions about whether Ranglin could proceed without paying fees or without an original signature on his submission. The order closed the action in the Southern District of New York. The court also certified that any appeal would not be taken in good faith and denied fee-free status for an appeal. The order did not decide whether the Bureau of Prisons properly subtracted the 89 days of credit.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.