Ludwig v. Hill

Summary

The United States District Court for the Southern District of California dismissed without prejudice a state prisoner’s habeas petition brought under 28 U.S.C. § 2241. The court held that compassionate-release authority under 18 U.S.C. § 3582(c)(1)(A) applies to federal prisoners, and that a state prisoner challenging a state sentence must proceed under 28 U.S.C. § 2254.

Holdings

1. The federal compassionate-release provision in 18 U.S.C. § 3582(c)(1)(A)(i) authorizes federal courts to reduce the sentences of federal prisoners, not to order compassionate release from a state sentence.
2. A state prisoner attacking the validity of a state sentence may not proceed under 28 U.S.C. § 2241 and must bring the federal habeas action under 28 U.S.C. § 2254.

Questions Presented

1. Whether a state prisoner may seek compassionate release from a state sentence under the federal compassionate-release statute, 18 U.S.C. § 3582(c)(1)(A)(i).
2. Whether a state prisoner attacking the validity of a state-court sentence may proceed under 28 U.S.C. § 2241 rather than 28 U.S.C. § 2254.

Disposition

dismissed