Gina Champion-Cain v. Warden, FCI Pekin

Summary

The United States District Court for the Central District of Illinois denied Gina Champion-Cain’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ calculation and application of First Step Act time credits. The court held that the requested prerelease-custody placement was not cognizable in habeas corpus and, alternatively, that the petitioner had not shown an error in the BOP’s calculations. The court also concluded that any challenge concerning Second Chance Act placement was premature.

Holdings

1. A challenge to the timing or conditions of placement in prerelease custody, such as home confinement or placement in a residential reentry center, is not a cognizable habeas claim when it does not seek a quantum change in the level of custody or alter the fact or duration of confinement.
2. The petitioner failed to establish that the Bureau of Prisons incorrectly calculated her First Step Act time credits or prerelease-custody eligibility date.
3. A challenge to Second Chance Act prerelease placement was premature because the Bureau of Prisons had not yet conducted the required individualized review and the earliest possible placement date was not until November 2028.

Questions Presented

1. Whether a federal prisoner's challenge to the timing of placement in prerelease custody, including home confinement or placement in a residential reentry center, is cognizable in a petition for habeas corpus under 28 U.S.C. § 2241.
2. Whether the Bureau of Prisons incorrectly calculated Champion-Cain's First Step Act time credits.
3. Whether a challenge to future placement under the Second Chance Act was ripe for review.

Disposition

writ_denied