Dawn Bennett v. Warden David Paul

Summary

The United States District Court for the Eastern District of Kentucky denied Dawn Bennett’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court concluded that Bennett had not clearly shown that the Bureau of Prisons incorrectly calculated or applied her First Step Act time credits and rejected her requests for home confinement, compassionate release, relief concerning confinement conditions, and collateral review of her convictions. The action was dismissed and stricken from the court’s docket.

Holdings

1. Bennett was not entitled to habeas relief because she failed to clearly demonstrate that the Bureau of Prisons’ comprehensive time-credit assessment was incorrect or inconsistent with applicable law.
2. Bennett was not entitled to immediate home confinement because the Bureau of Prisons has discretion to determine a prisoner’s place of confinement.
3. A request for compassionate release must be presented to the sentencing court rather than to the district court adjudicating Bennett’s § 2241 petition.
4. Bennett’s conditions-of-confinement claims were not cognizable in this habeas action and had to be pursued in a standalone civil-rights action.
5. Claims collaterally attacking Bennett’s underlying federal convictions or sentence were not cognizable in this § 2241 proceeding.

Questions Presented

1. Whether Bennett demonstrated that the Bureau of Prisons incorrectly calculated or applied her First Step Act time credits.
2. Whether Bennett was entitled to immediate placement in home confinement under 18 U.S.C. §§ 3621(b) and 3624(c).
3. Whether claims seeking compassionate release, challenging conditions of confinement, or collaterally attacking the underlying conviction and sentence were cognizable in a § 2241 petition.

Disposition

dismissed