Kareem Shaw v. E. Rardin

Summary

The United States District Court for the Eastern District of Michigan denied Kareem Shaw’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court held that the Bureau of Prisons properly aggregated Shaw’s consecutive sentences under 18 U.S.C. § 3584(c) and correctly determined that his conviction for escape under 18 U.S.C. § 751(a) made him ineligible for First Step Act time credits.

Holdings

1. The BOP properly aggregated Shaw's consecutive escape sentence with his drug-conspiracy sentence for administrative purposes under 18 U.S.C. § 3584(c), including for determining eligibility for First Step Act time credits.
2. Shaw was ineligible for First Step Act earned time credits because his aggregated sentence included a conviction for escape under 18 U.S.C. § 751(a), a disqualifying offense under 18 U.S.C. § 3632(d)(4)(D)(xiv).

Questions Presented

1. Whether 18 U.S.C. § 3584(c) required the BOP to treat Shaw's consecutive sentences from separate criminal cases as a single aggregate term for administrative purposes.
2. Whether the aggregated sentence rendered Shaw ineligible for First Step Act earned time credits under 18 U.S.C. § 3632(d)(4)(D), because one of the convictions was for escape under 18 U.S.C. § 751(a).

Disposition

denied