Marvin Adams v. Warden John Gilley

Summary

The United States District Court for the Western District of Virginia denied Marvin Adams’s motions for default judgment, injunctive relief, expedited relief, and other ancillary relief in his pro se 28 U.S.C. § 2241 petition. The court granted the respondent’s motion for summary judgment, concluding that Adams had no constitutional entitlement to home confinement or halfway-house placement, that the Bureau of Prisons’ placement decision was not judicially reviewable, and that the Bureau had conducted the required statutory review. The court dismissed the matter in its entirety.

Holdings

1. Default judgment was properly denied because Adams had not first obtained an entry of default under Federal Rule of Civil Procedure 55(a), and the government's response delay did not independently justify default judgment.
2. Adams was not entitled to habeas relief based on his assertion that the Bureau of Prisons miscalculated his Federal Time Credits because he provided no evidence or reasoning demonstrating that the Bureau's calculations were erroneous or that he was entitled to earlier release.
3. A federal inmate has no constitutional right or protected liberty interest in placement in home confinement, a halfway house, or other particular pre-release custody, and the Bureau of Prisons's placement decision is not subject to judicial review under the First Step Act's designation provision.
4. The Bureau of Prisons satisfied its obligation to conduct the Second Chance Act's five-factor review, and the court lacked authority to review the substantive merits or thoroughness of that discretionary placement analysis.
5. Adams was not entitled to preliminary injunctive or expedited relief because he could not show a likelihood of success on the merits.

Questions Presented

1. Whether Adams was entitled to default judgment or to have his habeas petition granted as unopposed because the government did not initially respond within thirty days.
2. Whether the Bureau of Prisons's calculation of Adams's Federal Time Credits and projected release or placement dates entitled him to habeas relief.
3. Whether Adams had a constitutional or statutory right to placement in home confinement or a halfway house and whether the Bureau of Prisons's placement decision was subject to judicial review.
4. Whether the Bureau of Prisons conducted the required five-factor placement review under the Second Chance Act.
5. Whether Adams could obtain summary judgment, discovery-related relief, subpoenas, or preliminary injunctive relief.

Disposition

dismissed