Brogdon v. Graham

CourtDistrict Court, D. South Carolina
DecidedMay 29, 2025
Docket5:24-cv-01706
StatusUnknown

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

Bluebook
Brogdon v. Graham, (D.S.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA

Conell Brogdon, ) Case No.: 5:24-cv-01706-JD-KDW ) Petitioner, ) ) vs. ) ) ORDER AND OPINION Warden Graham, ) ) Respondent. ) )

This matter is before the Court on the Report and Recommendation (“Report”) of United States Magistrate Judge Kaymani D. West (DE 37), issued under 28 U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2) of the District of South Carolina. The Report concerns Respondent Warden Graham’s (“Respondent” or “Graham”) Motion to Dismiss, or in the alternative, Motion for Summary Judgment (DE 32), seeking to dismiss Petitioner Cornell Brogdon’s (“Petitioner” or “Brogdon”) habeas petition brought under 28 U.S.C. § 2241 (DE 1).1 A. Background The Report accurately outlines the relevant facts and legal standards, which the Court incorporates herein by reference. A brief summary is provided for context. Petitioner, currently incarcerated at FCI Williamsburg, filed a habeas petition under 28 U.S.C. § 2241 challenging the BOP’s computation of his federal sentence.

1 The recommendation has no presumptive weight, and the responsibility for making a final determination remains with the United States District Court. See Mathews v. Weber, 423 U.S. 261, 270-71 (1976). The court is charged with making a de novo determination of those portions of the Report and Recommendation to which specific objection is made. The court may accept, reject, or modify, in whole or in part, the recommendation made by the magistrate judge or recommit the matter with instructions. 28 U.S.C. § 636(b)(1). (DE 1 at 2.) He was arrested on June 18, 2014, by New York State authorities on charges of attempted murder. (DE 32-1 at 1.) While still in state custody, he was indicted on federal charges in the Eastern District of New York on July 15, 2015. (DE

32-1 at 1.) He was temporarily transferred to federal custody on July 16, 2015, but remained in primary state custody. (DE 32-1 at 2.) Petitioner was returned to New York state custody on April 18, 2016, and sentenced by the state court on May 12, 2016, to a 10-year term for attempted murder and a concurrent 5-year term for weapons possession. (DE 32-1 at 2.) On May 17, 2016, he was again transferred to federal custody and, on April 18, 2019, sentenced

to 210 months for racketeering conspiracy, with the federal sentence ordered to run concurrently with the undischarged state terms. (DE 32-1 at 2.) According to a BOP management analyst, the BOP computed the federal sentence to commence on April 18, 2019—the date of imposition—based on Petitioner’s continued primary custody by the state. (DE 32-1 at 2.) A designation letter was sent to the USMS designating the New York State Department of Corrections for service of the federal sentence. (DE 32-1 at 2.) Petitioner was returned

to state custody on October 1, 2019, completed his state sentence on January 3, 2023, and was then released to the exclusive custody of the USMS. (DE 32-1 at 2.) Petitioner contends he is entitled to credit against his federal sentence from May 12, 2016, through April 18, 2019, during which he was in federal custody. (DE 1; DE 1-1.) B. Report and Recommendation On February 4, 2025, the Magistrate Judge recommended granting Respondent’s motion for summary judgment and denying the habeas petition in full.

(DE 37.) The Magistrate Judge concluded that Petitioner’s federal sentence was properly calculated to commence on April 18, 2019, the date it was imposed, under 18 U.S.C. § 3585(a), and found no abuse of discretion in the BOP’s decision not to backdate the commencement through a nunc pro tunc designation, under 18 U.S.C. § 3621(b). (DE 37 at 6.) The Report further determined that Petitioner is not entitled to credit under

18 U.S.C. § 3585(b) for time spent in state custody before that date because the time had already been credited against his state sentence. The BOP appropriately applied existing credit principles, including limited dual credit exceptions under Willis v. United States, 438 F.2d 923 (5th Cir. 1971) and Kayfez v. Gasele, 993 F.2d 1288 (7th Cir. 1993), which resulted in Petitioner receiving 694 days of credit. Petitioner’s additional reliance on Setser v. United States, 566 U.S. 231, 233, 236 (2012), and United States v. Jenkins, 256 F. App’x 594 (4th Cir. 2007), was rejected, as those cases

address a sentencing court’s discretion to impose concurrent or consecutive sentences—not the BOP’s authority to award custody credit already applied to a separate sentence. (DE 37.) Petitioner objected to the Report on February 18, 2025. (DE 39.) C. Legal Standard To be actionable, objections to the Report and Recommendation must be specific. Failure to file specific objections constitutes a waiver of a party’s right to

further judicial review, including appellate review, if the recommendation is accepted by the district judge. See United States v. Schronce, 727 F.2d 91, 94 & n.4 (4th Cir. 1984). “The Supreme Court has expressly upheld the validity of such a waiver rule, explaining that ‘the filing of objections to a magistrate’s report enables the district judge to focus attention on those issues—factual and legal—that are at the heart of the parties’ dispute.’” Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315

(2005) (citing Thomas v. Arn, 474 U.S. 140, 147 (1985) (emphasis added)). In the absence of specific objections to the Report and Recommendation of the magistrate judge, this Court is not required to give any explanation for adopting the recommendation. See Camby v. Davis, 718 F.2d 198, 199 (4th Cir. 1983). D. Petitioner’s Objections Petitioner objects to the Magistrate Judge’s conclusion that he is not entitled to federal sentence credit for time served in state custody before the imposition of his

federal sentence. (DE 39.) Ostensibly, he argues that the record does not conclusively establish that he is ineligible for such credit and that the Bureau of Prisons (BOP) should have exercised its discretion to designate the state facility as the place of federal confinement, effectively rendering the federal and state sentences fully concurrent. Petitioner cites Setser v. United States, 566 U.S. 231 (2012), and Dotson v. Kizziah, 966 F.3d 443 (6th Cir. 2020), to argue that the BOP has authority under 18 U.S.C. § 3621

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Related

Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Tony Willis v. United States
438 F.2d 923 (Fifth Circuit, 1971)
David E. Camby v. Larry Davis James M. Lester
718 F.2d 198 (Fourth Circuit, 1983)
United States v. Edward Lester Schronce, Jr.
727 F.2d 91 (Fourth Circuit, 1984)
Michael D. Kayfez v. G.R. Gasele
993 F.2d 1288 (Seventh Circuit, 1993)
Setser v. United States
132 S. Ct. 1463 (Supreme Court, 2012)
United States v. Jenkins
256 F. App'x 594 (Fourth Circuit, 2007)
Eric Dotson v. Gregory Kizziah
966 F.3d 443 (Sixth Circuit, 2020)

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Bluebook (online)
Brogdon v. Graham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brogdon-v-graham-scd-2025.