Summary
The United States District Court for the District of Connecticut denied Amanda Mae Bachman’s petition for habeas relief under 28 U.S.C. § 2241. The court held that her return from prerelease custody to BOP incarceration was supported by disciplinary violations and was not shown to be retaliatory. The court also concluded that the BOP was properly applying her First Step Act time credits and that her prior allegations of abuse and retaliation did not establish an ongoing violation cognizable under § 2241.
Topics
Practice areas
Questions Presented
- Whether Bachman's past allegations of sexual abuse, retaliation, and mistreatment at facilities from which she had been transferred could support ongoing relief under § 2241.
- Whether Bachman's return from prerelease custody to BOP incarceration was unlawful because it resulted from First Amendment retaliation.
- Whether the BOP improperly refused to apply Bachman's First Step Act time credits toward prerelease custody, home confinement, or release.
- Whether Bachman was being held in violation of the First or Eighth Amendment or the First Step Act.
Holdings
- Section 2241 did not provide relief for Bachman's past allegations of sexual abuse, retaliation, or mistreatment because she was no longer subject to those conditions and did not show an ongoing illegal confinement resulting from them.
- Bachman failed to show that her return to FCI Danbury was unlawful First Amendment retaliation because the disciplinary record established a sufficient nonretaliatory basis for the action.
- Bachman failed to establish that the BOP improperly refused to apply her First Step Act time credits because the evidence showed that the BOP had calculated an anticipated release date using those credits.
- Bachman did not show that her custody at FCI Danbury violated the Eighth Amendment because the First Step Act credits were being properly applied and her return to custody was authorized.
Key quotations
“A writ of habeas corpus under § 2241 is available to a federal prisoner who does not challenge the legality of his sentence, but challenges instead its execution subsequent to his conviction.” (II.A)
“Accordingly, the Court considers only Petitioner’s allegations that suggest she is subject to ongoing illegal confinement.” (III)
Factual background
Bachman was serving a 135-month federal sentence for conspiracy to distribute more than fifty grams of amphetamine. After periods of incarceration at FMC Lexington and FCI Waseca, she was transferred in March 2024 to prerelease custody at a residential reentry center operated by Dismas Charities. Between March 28 and July 2, 2024, she was found to have committed six disciplinary infractions, after which the BOP returned her to FCI Danbury. The record showed that the BOP had calculated an anticipated release date using her First Step Act time credits, but she challenged the revocation of prerelease custody and alleged retaliation and constitutional violations.
Procedural history
Bachman filed a § 2241 petition challenging her return from residential reentry-center custody to BOP incarceration and the alleged failure to apply First Step Act time credits. The Court issued an order to show cause; the respondent filed a memorandum opposing relief, and Bachman filed no response. The Court denied the petition and directed the Clerk to close the case.