Karamchand Doobay v. Judge James D. Cain, Jr. and Warden Pate

No. 2:25-cv-01914 · United States District Court for the Western District of Louisiana, Lake Charles Division · January 22, 2026 · No. 2:25-cv-01914

Summary

The Report and Recommendation addresses Karamchand Doobay’s 28 U.S.C. § 2241 petition challenging the Bureau of Prisons’ removal of First Step Act time credits after the Department of Homeland Security issued a final order of removal. The court concludes that 18 U.S.C. § 3632(d)(4)(E) bars a prisoner subject to a final removal order from applying First Step Act time credits, regardless of when the credits were earned, and recommends denial and dismissal with prejudice.

Holdings

  1. A prisoner subject to a final order of removal is ineligible to apply any First Step Act time credits to his sentence, including credits earned before the final order of removal was entered.
  2. Doobay's petition failed to state a claim for relief under 28 U.S.C. § 2241.

Questions Presented

  1. Whether a prisoner subject to a final order of removal is ineligible to apply First Step Act time credits earned before the final order was entered.
  2. Whether the Bureau of Prisons' removal of previously posted First Step Act time credits stated a basis for relief under 28 U.S.C. § 2241.

Disposition

dismissed

Cases Cited (10)

  • Ortega v. Warden, FCI-Texarkana, No. 5:23-CV-107, 2025 WL 3618826 (E.D. Tex. Sept. 9, 2025)(followed)
  • Ortega v. Warden, FCI-Texarkana, No. 5:23-CV-107, 2025 WL 3618305 (E.D. Tex. Dec. 12, 2025)(followed)
  • Zuluaga v. Warden, FCI-Texarkana, No. 5:23-CV-128, 2025 WL 2632550 (E.D. Tex. July 11, 2025)(followed)
  • Zuluaga v. Warden, FCI-Texarkana, No. 5:23-CV-128, 2025 WL 2409198 (E.D. Tex. Aug. 20, 2025)(followed)
  • Chocon-Gomez v. King, Civil Action No. 24-cv-2737, 2024 U.S. Dist. LEXIS 238542, 2024 WL 5381457 (D. Minn. Sept. 26, 2024)(followed)
  • Jenkins v. Segal, No. 23-cv-425 (WMW/DTS), 2023 U.S. Dist. LEXIS 193751, 2023 WL 7131024, at *2 (D. Minn. Oct. 30, 2023)(followed)
  • Jenkins v. Segal, 2023 WL 11692933 (8th Cir. Dec. 1, 2023)(followed)
  • Quiceno v. Segal, No. 23-cv-358 (NEB/DJF), 2023 U.S. Dist. LEXIS 98954, 2023 WL 3855295, at *3 (D. Minn. Apr. 21, 2023)(followed)
  • Quiceno v. Segal, 2023 U.S. Dist. LEXIS 97916, 2023 WL 3853433 (D. Minn. June 6, 2023)(followed)
  • Douglass v. United Services Automobile Ass'n, 79 F.3d 1415, 1429-30 (5th Cir. 1996)(followed)

Cited In (0)

No citing cases on record yet.

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