Steele v. Warden of FCI-Schuylkill

Summary

The United States District Court for the Middle District of Pennsylvania dismissed Joseph Steele’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ treatment of First Step Act credits. The court held that Steele failed to exhaust the Bureau of Prisons’ administrative-remedy process and dismissed the petition without prejudice.

Holdings

1. Although § 2241 contains no express exhaustion requirement, exhaustion of administrative remedies generally applies to § 2241 claims in the Third Circuit.
2. Steele's petition had to be dismissed without prejudice because he did not pursue any Bureau of Prisons administrative remedy requests concerning his First Step Act credit claim before filing the action.
3. Exhaustion may be excused in rare circumstances, including when the issue is purely one of statutory construction or exhaustion would be futile, but Steele did not establish an applicable exception.

Questions Presented

1. Whether a federal prisoner bringing a § 2241 petition must exhaust the Bureau of Prisons' administrative-remedy process before seeking habeas review.
2. Whether Steele's failure to pursue any administrative remedies required dismissal of his challenge to the denial of First Step Act credits.

Disposition

dismissed