Williams v. Bureau of Prisons
- John Cronan
- 1:24-cv-00867
- U.S. District Court · Southern District of New York
- 4
In Williams v. Bureau of Prisons, Judge Tarnofsky transferred the petition to Pennsylvania and substituted Warden Sage as respondent without deciding its merits.
Daryl Williams and the respondents in his custody challenge; the case was moved to the Middle District of Pennsylvania, and Warden Jessica Sage was substituted as respondent.
What happened
In Williams v. Bureau of Prisons, Daryl Williams, representing himself, challenged the decision to move him from a halfway house back to a federal prison. He filed the petition while confined at the Wyatt Detention Facility in Rhode Island.
After filing, Williams was moved to USP Lewisburg in Pennsylvania. The respondents agreed to replace the existing respondents with USP Lewisburg Warden Jessica Sage and to transfer the case to the federal court in Pennsylvania.
Judge Robyn F. Tarnofsky directed the Clerk to substitute Warden Sage and transfer the case to the United States District Court for the Middle District of Pennsylvania. The order did not decide whether Williams’s challenge was legally valid.
The detailed version
- Williams v. Bureau of Prisons · No. 1:24-cv-00867
- John Cronan
- Mar. 20, 2024
Background
Daryl Williams, proceeding without a lawyer, filed a petition under 28 U.S.C. § 2241, a procedure used to challenge a person’s custody or the execution of a sentence. He challenged his transfer from a halfway house back to a federal prison. Williams filed the petition in the United States District Court for the District of Rhode Island. The case was later transferred to the Southern District of New York.
When the Southern District of New York ordered the parties to explain why the case should not be transferred back to Rhode Island, the respondents confirmed that Williams had been confined at the Wyatt Detention Facility in Rhode Island when he filed the petition. After filing, Williams was transferred to USP Lewisburg in the Middle District of Pennsylvania, where he remained at the time of the order. The respondents consented to transferring the case to the Middle District of Pennsylvania and to substituting Jessica Sage, the warden of USP Lewisburg, as respondent.
Court’s analysis
The court applied the “immediate custodian at the time of filing” rule. Under that rule, the proper respondent in a § 2241 petition is generally the official responsible for the petitioner’s custody when the petition is filed, and the proper venue is generally the district where the petitioner is confined. The court also explained that the government may waive objections under that rule and consent to a different respondent or venue. The court found that the proposed substitution and transfer would allow the case to proceed where Williams was then confined against his current custodian.
Ruling
Judge Robyn F. Tarnofsky directed the Clerk of Court to substitute Warden Jessica Sage of USP Lewisburg for the existing respondents and to transfer the case to the United States District Court for the Middle District of Pennsylvania. The order did not reach the merits of Williams’s challenge to his transfer from the halfway house to prison. The order also stated that it superseded the local rule requiring a seven-day delay before the Clerk could carry out the transfer.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.