Christopher Mathers v. Warden, FCI Greenville

Summary

The United States District Court for the Southern District of Illinois dismissed Christopher Mathers’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ assignment of PATTERN recidivism score points. The court held that the challenge was not cognizable in habeas because it did not presently affect the validity or duration of Mathers’s confinement. The court also held that Mathers had failed to exhaust the Bureau of Prisons’ administrative-remedy process, and dismissed the petition without prejudice.

Holdings

1. A challenge to the BOP's assignment of PATTERN recidivism-score points is not cognizable in a habeas petition because the alleged scoring error does not, on the facts alleged, challenge the validity or duration of confinement or presently entitle the petitioner to earlier release or other custody-related relief.
2. The petition was independently subject to dismissal because Mathers did not allege that he completed the BOP's required administrative-remedy process before filing his § 2241 petition.

Questions Presented

1. Whether a challenge to the BOP's assignment of PATTERN recidivism-score points, assertedly affecting the rate of earning First Step Act time credits, is cognizable in a § 2241 habeas petition.
2. Whether the petition had to be dismissed for failure to exhaust the BOP's four-tier administrative-remedy process.

Disposition

dismissed