Matthew John Olson v. J. Sage (Warden)

Summary

The United States District Court for the Middle District of Pennsylvania dismissed Matthew John Olson’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. Olson challenged the Bureau of Prisons’ calculation of credit for time served in North Dakota custody toward his federal sentence. The court held that he failed to fully exhaust the Bureau of Prisons’ administrative remedies and stated that, even if exhaustion had been satisfied, the credit claim would fail because the disputed state-custody time had been credited against another sentence.

Holdings

1. Olson failed to establish that he completed the Bureau of Prisons' administrative-remedy process because the record showed appeals only through the regional level and did not show that he filed an appeal with the BOP Central Office.
2. Even if Olson had exhausted his administrative remedies, the BOP properly determined that his federal sentence could not commence before the date imposed and, in this case, commenced when he surrendered to the BOP on February 15, 2017.
3. Olson was not entitled to federal prior-custody credit for the period from September 11, 2014, through August 6, 2015, because that time had been credited against his state parole-violation sentence.

Questions Presented

1. Whether Olson exhausted the Bureau of Prisons' multi-step administrative-remedy process before filing his § 2241 petition.
2. Whether the Bureau of Prisons properly calculated the commencement of Olson's federal sentence and his prior-custody credit under 18 U.S.C. § 3585.
3. Whether Olson could receive federal sentence credit for time in state custody that had already been credited against his state parole-violation sentence.

Disposition

dismissed