Joseph R. Vigil v. Warden J. Wadas

Vigil v. Wadas · United States District Court for the District of Colorado · March 13, 2026 · No. 25-cv-00361-CNS

Summary

The United States District Court for the District of Colorado denied Joseph R. Vigil’s amended application for a writ of habeas corpus under 28 U.S.C. § 2241 and dismissed the case with prejudice. The court held that although Vigil had earned 106 First Step Act time credits, the credits were not being applied because he remained classified as having a high risk of recidivism, and he had not shown that the Bureau of Prisons violated his rights.

Holdings

  1. First Step Act time credits earned through qualifying programming are not automatically applied to prerelease custody or supervised release; application requires satisfaction of the statutory eligibility conditions, including the applicable recidivism-risk requirements.
  2. Vigil was not entitled to habeas relief because he did not present a reasoned argument that the Bureau of Prisons violated his rights in administering his First Step Act time credits.

Questions Presented

  1. Whether Vigil was entitled to habeas relief under 28 U.S.C. § 2241 based on the Bureau of Prisons' calculation and application of First Step Act time credits.
  2. Whether earned First Step Act time credits must be applied to prerelease custody or supervised release when the prisoner remains at a high risk of recidivism and has not successfully petitioned the warden for application.

Disposition

dismissed

Cases Cited (5)

  • Haines v. Kerner, 404 U.S. 519, 520-21 (1972) (per curiam)(followed)
  • Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991)(followed)
  • Preiser v. Rodriguez, 411 U.S. 475, 484 (1973)(followed)
  • Palma-Salazar v. Davis, 677 F.3d 1031, 1035 (10th Cir. 2012)(followed)
  • McIntosh v. U.S. Parole Commission, 115 F.3d 809, 812 (10th Cir. 1997)(followed)

Cited In (0)

No citing cases on record yet.

Court Document

Open PDF
Loading document…