Urieta-Jaimes v. Jaimison
- Kenneth Karas
- 7:23-cv-08090
- U.S. District Court · Southern District of New York
- 3
In Urieta-Jaimes v. Jaimison, Judge Karas denied a petition challenging the denial of time credits because exhaustion was required and a firearm conviction made the petitioner ineligible.
The ruling directly affected Miguel Angel Urieta-Jaimes and upheld the Bureau of Prisons’ determination that his § 924(c) conviction made him ineligible to earn the time credits. It also addressed the eligibility of people serving sentences under that statutory provision.
What happened
In Urieta-Jaimes v. Jaimison, Miguel Angel Urieta-Jaimes challenged the Bureau of Prisons’ decision not to let him earn time credits under the First Step Act. He claimed the decision discriminated against him because he is not a U.S. citizen.
The court identified two reasons the petition failed. First, Urieta-Jaimes had not completed the Bureau of Prisons’ administrative review process, and the court rejected his claim that doing so would have been pointless. Second, the court ruled that his conviction under 18 U.S.C. § 924(c) legally barred him from earning those credits, regardless of his immigration status.
Judge Kenneth Karas denied the petition, entered judgment for the respondent, and closed the case. The court also declined to issue a certificate allowing an appeal and denied permission to appeal without paying filing fees.
The detailed version
- Urieta-Jaimes v. Jaimison · No. 7:23-cv-08090
- Kenneth Karas
- Jan. 29, 2024
Background
Miguel Angel Urieta-Jaimes filed a petition under 28 U.S.C. § 2241 challenging the Bureau of Prisons’ refusal to allow him to earn time credits under the First Step Act. He claimed that the Bureau of Prisons unlawfully denied him those credits because he is not a U.S. citizen.
The opinion states that the District of South Carolina sentenced Urieta-Jaimes on November 28, 2017, to a total of 157 months in prison for possessing methamphetamine with the intent to distribute and possessing a firearm during a drug crime.
Court’s analysis
The court held that Urieta-Jaimes had not exhausted the Bureau of Prisons’ administrative remedies. Exhaustion means completing the agency’s review process before asking a court to intervene. Urieta-Jaimes acknowledged that he had not done so, but argued that exhaustion should not be required because it would have been futile. The court rejected that argument, explaining that the Bureau of Prisons’ determination that he was ineligible under the First Step Act did not eliminate the need to use the administrative process. The court also stated that exhaustion would have given the agency an opportunity to develop the factual record.
The court separately ruled that the petition failed on the merits. Under 18 U.S.C. § 3632(d)(4)(D)(xxii), a person serving a sentence under 18 U.S.C. § 924(c) is ineligible to receive the time credits at issue. Because Urieta-Jaimes had a § 924(c) conviction, the court concluded that his conviction—not his immigration status—made him ineligible for the credits.
The court also rejected his equal-protection claim. It found a rational basis for treating people convicted of offenses excluded by the statute differently from people convicted of other offenses. The court stated that Urieta-Jaimes provided no other basis for showing unlawful unequal treatment.
Disposition
The court denied the § 2241 petition and entered judgment for the respondent. It concluded that the case did not make a substantial showing that a constitutional right had been denied, so it did not issue a certificate of appealability. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without paying filing fees. The case was closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.