Juan Manuel Simental-Lopez v. Warden, FCI Mendota

Summary

The document is a magistrate judge’s Findings and Recommendation in a federal prisoner’s 28 U.S.C. § 2241 habeas proceeding challenging the Bureau of Prisons’ use of supervised-release revocation and related conduct in calculating the petitioner’s PATTERN score and eligibility to apply First Step Act earned time credits. The court recommends granting the respondent’s motion to dismiss in part and dismissing the petition, concluding that the earned-credit claim is unripe and that the BOP’s recidivism-risk determination is not reviewable under § 2241. The document also directs the Clerk of Court to assign a district judge and update the petitioner’s address.

Holdings

1. The claim was unripe because petitioner had not earned First Step Act credits in an amount equal to the remainder of his imposed term of imprisonment and therefore was not yet eligible to apply those credits under 18 U.S.C. § 3624(g)(1)(A).
2. Petitioner's challenge to the BOP's assessment of his recidivism risk level and related PATTERN eligibility determination was not reviewable in a § 2241 habeas petition because 18 U.S.C. § 3625 bars judicial review of determinations made under 18 U.S.C. §§ 3621–3624, absent a claim that the BOP violated the Constitution, acted contrary to established federal law, or exceeded its statutory authority.
3. Dismissal was not warranted on the asserted lack-of-standing ground because petitioner was challenging his custody classification and the effect of the PATTERN scoring decision, rather than merely seeking an award of earned time credits on an unconnected basis.

Questions Presented

1. Whether petitioner's challenge to the application of First Step Act earned time credits was ripe when his earned credits did not equal the remainder of his imposed sentence.
2. Whether a federal prisoner's § 2241 petition may challenge the Bureau of Prisons' discretionary PATTERN risk assessment and custody classification decisions under 18 U.S.C. §§ 3621–3624.
3. Whether dismissal was warranted for lack of standing.
4. Whether the challenged BOP treatment of petitioner's offense and supervised-release history violated the Constitution, established federal law, or the agency's statutory authority.

Disposition

dismissed