Guevara v. Keyes

Summary

The United States District Court for the Middle District of Alabama denied John Anthony Guevara’s petition for habeas corpus under 28 U.S.C. § 2241. The court held that the Bureau of Prisons properly aggregated his consecutive sentences, including a sentence under 18 U.S.C. § 924(c), for administrative purposes and therefore correctly determined that he was ineligible for First Step Act time credits. The case was dismissed with prejudice without an evidentiary hearing.

Holdings

1. The Bureau of Prisons properly aggregated Guevara's consecutive sentences for administrative purposes, and because the aggregated sentence included a § 924(c) conviction, Guevara was ineligible to receive First Step Act time credits.
2. No evidentiary hearing was required because the pertinent facts were fully developed in the record and Guevara identified no evidence necessitating a hearing.

Questions Presented

1. Whether the Bureau of Prisons may aggregate consecutive sentences, including a sentence for a disqualifying § 924(c) conviction, when determining eligibility for First Step Act time credits.
2. Whether Guevara was entitled to an evidentiary hearing on his § 2241 petition.

Disposition

dismissed