Raymond Justis v. C. Carter, Warden

Summary

The United States District Court for the District of Maryland denied Raymond Justis’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ refusal to award him First Step Act time credits. The court held that Justis’s conviction under 18 U.S.C. § 1591 independently rendered him ineligible for those credits, notwithstanding his accompanying conviction under 18 U.S.C. § 1594. The court also rejected his challenge to the Bureau’s offense-code designation and ordered the case closed.

Holdings

1. A prisoner serving a sentence for a conviction under 18 U.S.C. § 1591 is statutorily ineligible to earn First Step Act Time Credits even when the same sentence also includes a conviction under § 1594, which is excepted from the statutory exclusion.
2. Justis was not entitled to habeas relief based on the challenged offense-code designation because his § 1591 conviction independently barred him from earning FSA Time Credits, regardless of any alleged error in the designation.
3. A claim seeking credit against a sentence that challenges computation or execution of the sentence rather than the sentence itself may be brought under § 2241 in the district of confinement.

Questions Presented

1. Whether a prisoner convicted under both 18 U.S.C. § 1591 and § 1594 is eligible to earn First Step Act Time Credits because § 1594 is excepted from the statutory exclusions.
2. Whether the Bureau of Prisons improperly denied eligibility based on an offense code stating that the prisoner financially benefited from participation in a venture.
3. Whether the challenge to the computation and execution of the sentence was properly brought under 28 U.S.C. § 2241 in the district of confinement.

Disposition

denied