Summary
The Ninth Circuit reversed the dismissal of Leon Gonzalez’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court held that earned time credits under the First Step Act may be applied to reduce the length of a term of supervised release, and remanded for recalculation of Gonzalez’s credits and related relief.
Topics
Practice areas
Questions Presented
- Whether Gonzalez's release from Bureau of Prisons custody mooted his § 2241 petition when he continued to seek application of earned time credits to his supervised-release term.
- Whether 18 U.S.C. § 3632(d)(4)(C) permits earned First Step Act time credits to reduce the length of a term of supervised release, rather than merely accelerate the beginning of supervised release or prerelease custody.
- Whether the district court erred by dismissing Gonzalez's § 2241 petition.
Holdings
- Gonzalez's release from Bureau of Prisons custody did not moot his § 2241 petition because he remained in custody for habeas purposes while on supervised release and continued to seek relief affecting that supervised-release term.
- Under 18 U.S.C. § 3632(d)(4)(C), earned First Step Act time credits may be applied to reduce the length of a supervised-release term.
- The absence of a more detailed statutory procedure does not defeat the plain-language authorization to apply earned time credits to reduce supervised release.
Key quotations
“Therefore, heeding § 3632(d)(4)(C)’s plain language, we conclude that earned time credits shall be applied to reduce the length of a supervised release term.” (14)
“First, it declares that earned time credits shall reduce time in prerelease custody or supervised release, separate and apart from imprisonment.” (18)
“The Government simply disagrees with the policy chosen by Congress, and “it is not [the court’s] role to choose what [it] think[s] is the best policy outcome and to override the plain meaning of a statute, apparent anomalies or not.”” (28)
Factual background
Gonzalez was sentenced to 120 months of imprisonment and five years of supervised release for conspiracy to distribute controlled substances. He participated in First Step Act recidivism-reduction programs while incarcerated and on home confinement and earned 610 time-credit days. The Bureau of Prisons applied 237 days to end his custodial sentence but left 373 days unused, refusing to apply them to reduce his supervised-release term. After unsuccessful administrative appeals, Gonzalez sought relief under § 2241.
Procedural history
Gonzalez was sentenced in the Central District of California to 120 months of imprisonment and five years of supervised release. After earning 610 First Step Act time-credit days, the Bureau of Prisons applied 237 days to his custodial sentence but refused to apply the remaining 373 days to reduce his supervised-release term. Gonzalez exhausted the Bureau of Prisons' administrative process, filed a § 2241 petition, and the district court dismissed it on April 2, 2024. The Ninth Circuit reversed and remanded with instructions to grant the petition in part and require recalculation of the credits and delivery of the recalculation to Gonzalez's probation officer.
Remand instructions
Grant Gonzalez's § 2241 petition in part, direct the Government to recalculate his earned First Step Act time credits, and provide the recalculation to Gonzalez's probation officer.