Naim Taylor v. Warden of FCI Schuylkill

Summary

The United States District Court for the Middle District of Pennsylvania dismissed with prejudice Naim Taylor’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. Taylor challenged the Bureau of Prisons’ determination that his firearm enhancement made him ineligible for a sentence reduction upon completion of the Residential Drug Abuse Treatment Program. The court held that the Supreme Court’s decision in Lopez v. Davis foreclosed his challenge to the relevant BOP regulation and policies.

Holdings

1. The BOP may exercise its statutory discretion to categorically exclude inmates whose current felony offense involved carrying, possessing, or using a firearm from eligibility for an early-release sentence reduction under 18 U.S.C. § 3621(e)(2)(B).
2. Taylor's two-level firearm-possession enhancement did not entitle him to an RDAP sentence reduction or invalidate the BOP's exclusion of him from early-release consideration.
3. Taylor was not entitled to habeas relief because the face of his petition and its attachments showed that his challenge was foreclosed by controlling precedent.

Questions Presented

1. Whether the BOP's regulation, 28 C.F.R. § 550.55(b)(5)(ii), exceeded the BOP's statutory authority or conflicted with 18 U.S.C. § 3621(e)(2)(B) by categorically excluding inmates whose felony offense involved carrying, possessing, or using a firearm from consideration for an RDAP sentence reduction.
2. Whether the BOP could rely on Taylor's two-level USSG § 2D1.1(b)(1) firearm-possession enhancement to deny eligibility for an RDAP sentence reduction.
3. Whether Taylor was entitled to relief under 28 U.S.C. § 2241.

Disposition

dismissed