Mario Satizabal v. C. Edge

Summary

The United States District Court for the Eastern District of Arkansas adopted a magistrate judge’s recommendation and dismissed Mario Satizabal’s 28 U.S.C. § 2241 petition. The court held that the Bureau of Prisons properly deemed him ineligible for First Step Act earned time credits because his aggregated sentence included a conviction for possessing contraband in prison, a disqualifying offense under 18 U.S.C. § 3632(d)(4)(D)(xxix). The court overruled Satizabal’s objections and dismissed the petition.

Holdings

1. The Bureau of Prisons correctly determined that Satizabal's misdemeanor and felony sentences had to be aggregated.
2. The First Step Act's list of disqualifying offenses includes an offense under 18 U.S.C. § 1791 relating to providing or possessing contraband in prison, so the Bureau of Prisons properly denied Satizabal earned time credits.

Questions Presented

1. Whether the Bureau of Prisons properly aggregated Satizabal's misdemeanor sentence for possessing contraband in prison with his felony cocaine sentence.
2. Whether the First Step Act's list of disqualifying offenses includes an offense under 18 U.S.C. § 1791 relating to providing or possessing contraband in prison when the sentence is aggregated with another sentence.

Disposition

dismissed