Edgar Manuel Sierra-Serrano v. Warden, FCI Sandstone

Summary

The United States District Court for the District of Minnesota adopts a magistrate judge’s Report and Recommendation and denies Edgar Manuel Sierra-Serrano’s habeas petition concerning the calculation of good conduct time, First Step Act credits, Second Chance Act credits, and his projected Conditional Transition to Community date. The court concludes that the alleged future injury is speculative and dismisses the petition without prejudice for lack of jurisdiction.

Holdings

1. A petitioner's claim concerning future prison-credit calculations and a projected transition date does not establish Article III standing when the alleged harm depends on events that may or may not occur and on discretionary Bureau of Prisons action.
2. Dismissal based solely on lack of jurisdiction is without prejudice.
3. The court and Clerk's Office could not calculate the petitioner's First Step Act credits because they lacked the necessary information; the Bureau of Prisons must perform the initial calculation.

Questions Presented

1. Whether the petition presented an actual case or controversy under Article III when the claimed injury depended on uncertain future events and discretionary Bureau of Prisons action.
2. Whether the petition should be dismissed without prejudice when the court lacked jurisdiction because the asserted harm was speculative.
3. Whether the court or Clerk's Office could calculate the petitioner's First Step Act credits based on the information before the court.

Disposition

dismissed