Summary
The United States District Court for the Eastern District of Missouri considers Donyell M. Coleman's petition for habeas corpus under 28 U.S.C. § 2241. Coleman seeks early termination of supervised release based on Federal Time Credits earned under the First Step Act. The court requests briefing on whether those credits may reduce the length of supervised release, an issue on which the federal circuits have divided.
Questions Presented
- Whether Coleman remains in custody for purposes of § 2241 while serving supervised release.
- Whether Federal Time Credits under 18 U.S.C. § 3632(d)(4)(C) may be applied to reduce the length of a supervised-release term.
- Whether the government should be required to brief the unresolved statutory issue because the Eighth Circuit had not decided it.
Disposition
other
Cases Cited (8)
- Hargrove v. Healy, 155 F.4th 530 (6th Cir. 2025)(followed for description of split)
- Guerriero v. Miami RRM, 2024 WL 2017730 (11th Cir. May 7, 2024) (per curiam)(followed for description of split)
- United States v. Malik, 2025 WL 973003 (4th Cir. Apr. 1, 2025) (per curiam)(followed for description of split)
- Stinson v. Martinez, 2025 WL 2017872 (5th Cir. July 18, 2025) (per curiam)(followed for description of split)
- Valladares v. Ray, 130 F.4th 74 (4th Cir. 2025)(followed for description of split)
- Gonzalez v. Herrera, 151 F.4th 1076, 1089 (9th Cir. 2025)(followed for description of split)
- Wilson v. Fikes, 2019 WL 7593244, at *2 (D. Minn. Aug. 27, 2019), report and recommendation adopted, 2019 WL 6318621, at *1 (D. Minn. Nov. 26, 2019)(relied upon)
- United States v. Coleman, No. 4:13-CR-00487-SEP (E.D. Mo.)(background)
Cited In (0)
No citing cases on record yet.
Court Document
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