Louis Goldenberg v. Warden Heuett

Summary

The United States District Court for the Southern District of Florida denied without prejudice Louis Goldenberg’s petition for habeas relief under 28 U.S.C. § 2241. The court held that Goldenberg failed to exhaust the Bureau of Prisons’ administrative-remedy process before challenging the date on which he became eligible to earn First Step Act Earned Time Credits, and rejected his argument that exhaustion would be futile.

Holdings

1. The petition must be denied without prejudice because Goldenberg conceded that he had not exhausted the BOP's administrative remedy process and did not appeal the Warden's denial to the Regional Director.
2. Goldenberg did not establish an exception to exhaustion based on futility or the asserted statutory-interpretation nature of his claim.

Questions Presented

1. Whether the § 2241 petition had to be denied because Goldenberg failed to complete the Bureau of Prisons' administrative remedy process before filing.
2. Whether alleged futility or the asserted statutory-interpretation nature of the First Step Act credit issue excused exhaustion.

Disposition

dismissed