Summary
This memorandum opinion from the United States District Court for the Middle District of Pennsylvania addresses a habeas corpus petition challenging the Bureau of Prisons' denial of First Step Act time credits. The court held that because the petitioner was convicted of a firearm offense under 18 U.S.C. § 924(c), he is statutorily ineligible for credits. Relying on 18 U.S.C. § 3584(c), the court concluded that consecutive sentences must be aggregated into a single term, thereby triggering the ineligibility provision regardless of how the sentences are structured. The petition was accordingly denied.
Topics
Practice areas
Questions Presented
- Whether a prisoner serving consecutive sentences, including a conviction enumerated in 18 U.S.C. § 3632(d)(4)(D), is ineligible for First Step Act time credits for the entire aggregate term of imprisonment.
Holdings
- The petition is denied; the Bureau of Prisons correctly deemed Iverson ineligible for First Step Act time credits for the entire aggregate term of imprisonment.
Key quotations
“Under Section 3584, “Multiple terms of imprisonment ordered to run consecutively or concurrently shall be treated for administrative purposes as a single, aggregate term of imprisonment.” 18 U.S.C. § 3584(c).”
“The petition for writ of habeas corpus is denied. An appropriate order shall issue.”
Factual background
Elijah Iverson is serving a 180‑month sentence for drug‑related offenses and a firearm conviction under 18 U.S.C. § 924(c). The Bureau of Prisons deemed him ineligible for First Step Act earned time credits because of the § 924(c) conviction. Iverson argued the ineligibility should apply only to the portion of his sentence attributable to that conviction.
Procedural history
Petitioner filed a habeas petition on September 16, 2024. The case was initially assigned to Judge Christopher C. Conner and later reassigned to Judge Keli M. Neary on January 21, 2025. The Bureau of Prisons denied time‑credit eligibility under the First Step Act, and the district court denied the petition.