Benjamin Macias v. Bradley

CourtDistrict Court, C.D. California
DecidedNovember 10, 2020
Docket2:20-cv-07114
StatusUnknown

This text of Benjamin Macias v. Bradley (Benjamin Macias v. Bradley) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benjamin Macias v. Bradley, (C.D. Cal. 2020).

Opinion

1 JS-6 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION 11 12 BENJAMIN MACIAS, ) No. CV 20-7114-RGK (PLA) ) 13 Petitioner, ) ) ORDER DISMISSING CASE 14 v. ) ) 15 PATRICIA V. BRADLEY, Complex ) Warden, ) 16 ) Respondent. ) 17 __________________________________) 18 I. 19 PROCEEDINGS 20 On August 3, 2020, petitioner filed a Request for Compassionate Release based on the 21 ongoing COVID-19 pandemic. (ECF No. 1). On August 25, 2020, respondent filed a Motion 22 seeking to dismiss or transfer the matter. (ECF No. 5). On September 21, 2020, petitioner filed 23 a Reply to the Motion, in which he alleges constitutional violations and asks the Court to construe 24 his request for compassionate release as a habeas petition pursuant to 28 U.S.C. § 2241. (ECF 25 No. 8). The Magistrate Judge ordered respondent to file a response addressing petitioner’s 26 purported habeas claims. (ECF No. 9). On October 14, 2020, respondent filed a Response. 27 (ECF No. 10). 28 / 1 II. 2 SUMMARY 3 In November 2018, pursuant to a jury trial in the United States District Court for the Eastern 4 District of California, petitioner was convicted of the following crimes: conspiracy to distribute, and 5 to possess with intent to distribute, cocaine (21 U.S.C. §§ 841(a)(1), 846); distribution of cocaine 6 (21 U.S.C. § 841(a)(1)); possession with intent to distribute cocaine (21 U.S.C. § 841(a)(1)); and 7 felon in possession of a firearm (18 U.S.C. § 922(g)(1)). (ECF No. 5 at 12, 39, 62). He was 8 sentenced to a term of 146 months in federal prison. (Id. at 62-63). Petitioner appealed his 9 conviction and sentence, and on June 16, 2020, the Ninth Circuit denied the appeal. (Id. at 71- 10 76). Petitioner is currently housed at United States Penitentiary - Lompoc (“USP-Lompoc”). (See 11 ECF No. 8 at 1). 12 On August 3, 2020, petitioner filed a Request for Compassionate Release pursuant to 18 13 U.S.C. § 3582(c)(1)(A). (ECF No. 1). Petitioner alleges that because he has asthma and 14 hypertension, he “falls into the CDC’s guidelines for being a high risk individual for complications 15 from COVID-19.” (Id. at 9). He asserts that “extraordinary or compelling circumstances” warrant 16 his compassionate release, such as “the imminent threat of possible infection and[/]or death” from 17 the “COVID-19 disease outbreak at USP-Lompoc,” the failure by prison officials to control the 18 outbreak, and the fact he is “subject to administratively forced double inmate cell occupancy.” (Id. 19 at 17-18). Petitioner also requests release to home confinement. He cites a Memorandum issued 20 by Attorney General William Barr on April 3, 2020, in which the Attorney General found that 21 “emergency conditions are materially affecting the functioning of the Bureau of Prisons.” (Id. at 22 2). This finding, petitioner argues, “invokes . . . the CARES Act (2020), length[en]ing the maximum 23 amount of time a prisoner can be placed into home confinement under 18 U.S.C. 3624.”1 (Id.). 24 25 1 On March 27, 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security 26 Act (“CARES Act”), which authorized the Director of the BOP “to lengthen the amount of time prisoners can be placed on home confinement under [18 U.S.C.] § 3624(c)(2) provided that the 27 Attorney General makes a finding that ‘emergency conditions will materially affect the functioning of the Bureau.’” Wilson v. Ponce, __ F.Supp.3d __, 2020 WL 3053375, at *6 (C.D. Cal. June 8, 28 1 Petitioner asserts that the BOP improperly denied his numerous requests for home confinement, 2 as he meets the BOP’s eligibility criteria and because additional factors -- such as the nature of 3 his commitment offense, his institutional behavior, and the length of his prison term he has already 4 served -- indicate home confinement is proper in his case. (Id. at 2-17). 5 In the instant Motion, respondent asserts the Court lacks jurisdiction to grant petitioner’s 6 request for compassionate release under 18 U.S.C. § 3582(c) because only the sentencing court 7 may order such relief. (ECF No. 5 at 6-8). Respondent further contends the Court lacks 8 jurisdiction to entertain petitioner’s request for home confinement because, pursuant to 18 U.S.C. 9 § 3624(c), the BOP has the exclusive authority to determine where an inmate is placed. (Id. at 10 9-10). 11 In his Reply to the Motion, petitioner asks the Court to liberally construe his Request for 12 Compassionate Release as a habeas action that challenges the “fact or duration” of his 13 confinement under 28 U.S.C. § 2241. (ECF No. 8 at 2). In support, petitioner claims that, given 14 the COVID-19 outbreak at USP-Lompoc and his medical condition, his current confinement 15 amounts to “cruel and unusual punishment” in violation of the Eighth Amendment. He also raises 16 due process and equal protection claims, and sets forth numerous allegations describing how 17 prison officials have failed to enforce adequate pandemic-related safety protocols at USP-Lompoc. 18 (Id. at 3-13). Although petitioner again argues that home confinement is warranted, he also 19 requests that the Court grant a restraining order against respondent, and custody credits at the 20 rate of two and one-half days for every day petitioner has served. (Id. at 4-5, 7, 13). 21 The Magistrate Judge ordered respondent to address the purported habeas claims. In his 22 Response, respondent asserts that petitioner’s new claims attack the conditions of his confinement 23 -- not the fact or duration of his confinement. As a result, petitioner’s constitutional claims sound 24 in civil rights, and not habeas. Respondent therefore contends that dismissal of petitioner’s 25 constitutional claims is warranted, as the claims exceed the Court’s jurisdiction under § 2241. 26 (ECF No. 10 at 5-6). 27 / 28 / 1 III. 2 DISMISSAL IS WARRANTED 3 The Court first addresses petitioner’s request seeking compassionate release. Under 18 4 U.S.C. § 3582(c)(1)(A)(i), a sentencing court may, upon motion of the BOP Director or upon 5 motion of the defendant, reduce a defendant’s term of imprisonment if it finds that “extraordinary 6 and compelling reasons warrant such a reduction.” Such a motion seeking compassionate release 7 must be addressed to the sentencing court. See United States v. Raia, 954 F.3d 594, 596 (3d Cir. 8 2020) (“Section 3582’s text requires [compassionate-release] motions to be addressed to the 9 sentencing court, a point several Circuits have noted[.]”); Bolden v. Ponce, 2020 WL 2097751, at 10 *2 (C.D. Cal. May 1, 2020) (federal inmate must file motion for compassionate release in the 11 original sentencing court). Here, because petitioner was sentenced in the Eastern District of 12 California, this Court lacks jurisdiction to entertain his compassionate-release request.

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