Asa Nall v. Warden H.L. Ray

CourtDistrict Court, S.D. Georgia
DecidedJanuary 22, 2026
Docket2:25-cv-00042
StatusUnknown

This text of Asa Nall v. Warden H.L. Ray (Asa Nall v. Warden H.L. Ray) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Asa Nall v. Warden H.L. Ray, (S.D. Ga. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

ASA NALL,

Petitioner, CIVIL ACTION NO.: 2:25-cv-42

v.

WARDEN H.L. RAY,

Respondent.

REPORT AND RECOMMENDATION Petitioner Asa Nall (“Nall”), who is currently incarcerated at the Federal Correctional Institution-Low in Jesup, Georgia, filed a 28 U.S.C. § 2241 Petition for Writ of Habeas Corpus. Doc. 1. Respondent filed a Motion to Dismiss Nall’s Petition, and Nall filed a Response. Docs. 6, 11. For the following reasons, I RECOMMEND the Court GRANT Respondent’s Motion to Dismiss and DISMISS without prejudice Nall’s Petition based on his failure to exhaust his administrative remedies. I also RECOMMEND the Court DIRECT the Clerk of Court to CLOSE this case and enter the appropriate judgment of dismissal and DENY Nall in forma pauperis status on appeal. BACKGROUND Nall was convicted in the District Court for the Middle District of Florida of attempted enticement of a minor, in violation of 18 U.S.C. § 2422(b). Doc. 7-1 at 6. Nall was sentenced to 120 months in prison. Nall has a statutory release date of April 22, 2028, via good conduct release, and a projected release date of April 23, 2027, via First Step Act (“FSA”) release. Id. Nall is eligible for home detention on October 22, 2026. Id. In his Petition, Nall asserts that the Bureau of Prisons (“BOP”) has not properly credited his sentence under the FSA, in accordance with the clear language of 18 U.S.C. § 3624(g).

Doc. 1 at 6, 11. Nall also states that the BOP has illegally denied his credits under the Second Chance Act (“SCA”). Id. at 6, 12– 13. Nall essentially asks the Court to order the BOP to apply his earned time credits. Id. at 15. Respondent asks this Court to dismiss Nall’s Petition because Nall failed to exhaust his administrative remedies regarding the claims he raises in this Petition. Doc. 7 at 2–5. Respondent also states that this Court lacks jurisdiction under the Administrative Procedures Act to review Nall’s FSA claims and that the SCA does not authorize this Court to order Nall to serve his sentence at a different location. Id. at 5–11. DISCUSSION I. Nall Did Not Exhaust His Available Administrative Remedies Respondent asserts that Nall filed an administrative remedy request at the BP-9 level

(Warden or institutional level) but did not file a request at the BP-10 or BP-11 levels (Regional and Central Office levels), both of which are required to complete exhaustion. Doc. 7 at 4. Because Nall failed to complete this process, Respondent asserts his Petition should be dismissed. Id. at 5. Nall states that the BOP’s denial of his FSA credits “violates the law and exhaustion is not required.” Doc. 11 at 1. Nall also states that the BOP continually relies on Program Statement 5410.01 to deny inmates their full earned credits and the BOP’s reliance on the Statement makes administrative remedies “unavailable” and a “dead end.” Id. at 2. Liberally construing Nall’s assertions, Nall is arguing that he should be excused from exhausting administrative remedies for two reasons. First, Nall argues that exhaustion is not required because the BOP violated the law. Second, Nall asserts that the BOP’s reliance on Program Statement 5410.01 to deny requests for FSA credits renders the administrative remedies

process unavailable and is a dead end. The Court addresses each argument. A. Generally, a Petitioner Must Fully Exhaust All Available Administrative Remedies Before Filing a § 2241 Petition The Eleventh Circuit Court of Appeals has held a § 2241 petitioner’s failure to exhaust administrative remedies is not a jurisdictional defect. Santiago-Lugo v. Warden, 785 F.3d 467, 474 (11th Cir. 2015); see also Fleming v. Warden of FCI Tallahassee, 631 F. App’x 840, 842 (11th Cir. 2015) (“[Section] 2241’s exhaustion requirement was judicially imposed, not congressionally mandated, and . . . nothing in the statute itself support[s] the conclusion that the requirement [is] jurisdictional.”). Nevertheless, the Eleventh Circuit has noted “the exhaustion requirement [is] still a requirement and that courts cannot ‘disregard a failure to exhaust . . . .’” Fleming, 631 F. App’x at 842 (citing Santiago-Lugo v. Warden, 785 F.3d 467, 475 (11th Cir. 2015)). Exhaustion of administrative remedies must occur first in the agency setting to allow “the agency [to] develop the necessary factual background upon which decisions should be based” and to give “the agency a chance to discover and correct its own errors.” Green v. Sec’y for Dep’t of Corr., 212 F. App’x 869, 871 (11th Cir. 2006) (quoting Alexander v. Hawk, 159 F.3d

1321, 1327 (11th Cir. 1998) (first alteration in original)). Furthermore, requiring exhaustion in the prison setting “eliminate[s] unwarranted federal-court interference with the administration of prisons” and allows “corrections officials time and opportunity to address complaints internally before allowing the initiation of a federal case.” Woodford v. Ngo, 548 U.S. 81, 93 (2006).1 The United States Supreme Court has noted exhaustion must be “proper.” Id. at 92. “Proper exhaustion demands compliance with an agency’s deadlines and other critical procedural

rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings.” Id. at 90–91. In other words, an institution’s requirements define what is considered exhaustion. Jones v. Bock, 549 U.S. 199, 218 (2007). The Eleventh Circuit has explained—though only in an unpublished opinion—that a § 2241 petitioner need only exhaust “available” administrative remedies. Blevins v. FCI Hazelton Warden, 819 F. App’x 853, 856 (11th Cir. 2020) (citing Ross v. Blake, 578 U.S. 632 (2016)). As a result, a petitioner need not exhaust administrative remedies: (1) where despite what regulations or guidance materials may promise, the administrative process operates as a simple dead end––with officers unable or consistently unwilling to provide any relief to aggrieved inmates, (2) where the administrative process is “so opaque that it becomes, practically speaking, incapable of use” because “no ordinary prisoner can discern or navigate it, and (3) where prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation. Id. (cleaned up); see also Parra-Orona v. Jenkins, No. 1:23-CV-2434, 2024 WL 6083897, at *2 (N.D. Ga. Jan. 16, 2024) (citing Blevins and evaluating the unavailability of administrative remedies in the § 2241 context), adopted by, 2024 WL 6083898 (N.D. Ga. Mar. 26, 2024); Ridling v. Yeager, No. 1:24-CV-01785, 2025 WL 1892707, at *3 (N.D. Ala. June 13, 2025) (same), adopted by, 2025 WL 1885636 (N.D. Ala. July 8, 2025).

1 Although Woodford was a civil rights suit rather than a habeas petition, the Court “noted that the requirement of exhaustion is imposed by administrative law in order to ensure that the agency addresses the issues on the merits.” Fulgengio v. Wells, CV309-26, 2009 WL 3201800, at *4 (S.D. Ga. Oct. 6, 2009) (emphasis in original) (quoting Woodford, 548 U.S. at 90) (internal punctuation omitted). Thus, exhaustion requirements are applicable to habeas petitions.

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