Omar S. Folk v. Warden McKean A. Newman

Summary

The court denied Omar S. Folk’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court held that challenges to prison educational programming, security classification, and prison conditions do not concern the fact or duration of confinement and therefore are not cognizable under § 2241. The court also concluded that Loper Bright Enterprises v. Raimondo did not alter that result and noted that Folk’s claims concerning FCI McKean were moot after his transfer.

Holdings

1. A federal prisoner's challenge to denial of prison educational programming and to a resulting security classification is not cognizable under § 2241 when it does not challenge the fact or duration of confinement.
2. Loper Bright Enterprises v. Raimondo does not make Folk's § 2241 claims cognizable because Loper Bright concerns judicial deference to agency interpretations of statutes challenged under the Administrative Procedure Act, not the habeas claims presented here.
3. Petitioner's transfer from FCI McKean to FCI Hazelton rendered moot his claims concerning lockdowns and conditions at FCI McKean.

Questions Presented

1. Whether a federal prisoner's challenge to denial of educational programming and a resulting security classification, which does not affect the fact or duration of confinement, is cognizable under 28 U.S.C. § 2241.
2. Whether Loper Bright Enterprises v. Raimondo makes the petition cognizable or otherwise changes the analysis of the Bureau of Prisons' implementation of the sentence.
3. Whether Petitioner's transfer from FCI McKean rendered his claims concerning lockdowns at that institution moot.

Disposition

writ_denied