Khan v. Lillard

Summary

The United States District Court for the Southern District of Illinois denied Khatija Khan’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. Khan sought First Step Act time credits for periods spent in administrative detention and on a federal writ, but the court concluded she had not shown successful participation in qualifying evidence-based recidivism reduction programming or productive activities during those periods. The matter was dismissed with prejudice and closed.

Holdings

1. Khan was not entitled to the claimed 44 days of First Step Act time credit because she failed to demonstrate that she successfully participated in evidence-based recidivism reduction programming or productive activities during the relevant periods.
2. The court did not need to decide whether the Bureau of Prisons' regulations conflicted with the First Step Act because Khan failed to establish the underlying factual prerequisite of successful participation in qualifying programming or activities.

Questions Presented

1. Whether Khan was entitled under the First Step Act to 44 days of time credit for periods of administrative detention and custody on a writ.
2. Whether Khan had established successful participation in evidence-based recidivism reduction programming or productive activities sufficient to earn the claimed credits.
3. Whether the court needed to resolve whether the Bureau of Prisons' regulations governing the availability of First Step Act time credits conflicted with the governing statute.

Disposition

dismissed