Pamela Renee Puckett v. Acting Warden

Summary

The United States District Court for the Southern District of Illinois dismissed Pamela Renee Puckett’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ calculation and application of First Step Act time credits. The court held that Puckett failed to exhaust available administrative remedies and that no exception justified excusing exhaustion. In the alternative, the court concluded that projected or additional credits could affect only the place of confinement, rather than the duration of custody, and therefore were not cognizable in a habeas petition.

Holdings

1. A federal prisoner challenging the Bureau of Prisons’ sentence or credit calculation must complete the available administrative-remedy process before seeking judicial review under § 2241, absent a recognized exception. Puckett did not exhaust because she failed to cure the deficient regional appeal and did not pursue a Central Office appeal, and no exception justified excusing exhaustion.
2. Projected, unearned First Step Act time credits may not be applied in calculating a federal prisoner’s release or placement date.
3. Once the statutory maximum of 365 First Step Act time-credit days has been applied toward early transfer to supervised release, additional credits cannot further shorten the prisoner’s sentence and may affect only the timing of pre-release custody.
4. A claim seeking only to accelerate placement in pre-release custody challenges the location or conditions of confinement rather than the fact or duration of confinement and is therefore not cognizable in a § 2241 habeas petition.

Questions Presented

1. Whether the court should excuse Puckett’s failure to exhaust the Bureau of Prisons’ administrative-remedy process before seeking relief under § 2241.
2. Whether projected, unearned First Step Act time credits may be applied to reduce a federal prisoner’s sentence.
3. Whether a claim seeking acceleration of pre-release custody based on additional or projected First Step Act credits is cognizable in a § 2241 habeas petition.

Disposition

dismissed