Freeman v. Cutright

CourtDistrict Court, S.D. West Virginia
DecidedSeptember 30, 2025
Docket1:24-cv-00449
StatusUnknown

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

Bluebook
Freeman v. Cutright, (S.D.W. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA AT BLUEFIELD

PRECIAS FREEMAN,

Petitioner,

v. CIVIL ACTION NO. 1:24-00449

CHRISTI CUTRIGHT,

Respondent.

MEMORANDUM OPINION AND ORDER

By Standing Order, this action was referred to United States Magistrate Judge Omar J. Aboulhosn for submission of findings and recommendation regarding disposition pursuant to 28 U.S.C. § 636(b)(1)(B). Magistrate Judge Aboulhosn submitted to the court his Proposed Findings and Recommendation (“PF&R”) on June 12, 2025, in which he recommended that the court grant respondent’s motion to dismiss or, in the alternative, motion for summary judgment, and remove this case from the court’s active docket. In accordance with the provisions of 28 U.S.C. § 636(b), petitioner was allotted fourteen days and three mailing days in which to file any objections to Magistrate Judge Aboulhosn’s Findings and Recommendation. The failure of any party to file such objections within the time allowed constitutes a waiver of such party’s right to a de novo review by this court. Snyder v. Ridenour, 889 F.2d 1363 (4th Cir. 1989). On July 7, 2025, petitioner timely submitted objections to the PF&R. See ECF No. 20. Petitioner is currently serving a 110-month term of imprisonment, imposed on March 23, 2023, by the United States

District Court for the District of South Carolina. See ECF No. 12-1 at 59-60. In 2016 and 2017, Freeman faced criminal charges in multiple jurisdictions, both state and federal. The PF&R lays out a detailed chronology of those charges and the corresponding court proceedings. As relevant here, Freeman was arrested on October 3, 2016, by the State of South Carolina on controlled substance offenses. On February 14, 2017, Freeman was indicted on a federal drug charge—conspiracy to possess with intent to distribute and distribute hydrocodone and oxycodone, in violation of 21 U.S.C. § 846—in the United States District Court for the District of South Carolina. The State of North Carolina indicted Freeman on drug trafficking charges on March

21, 2017. Freeman was released on bond by both the federal and state courts. However, she was rearrested by the State of North Carolina on March 1, 2018, on new controlled substance offenses. On December 13, 2018, the federal court sentenced Freeman to a term of imprisonment of 210 months. The judgment order did not mention the anticipated state sentences nor direct whether the federal sentence should run consecutively or concurrently to any subsequent sentence. After sentencing, Freeman was returned to North Carolina custody. More than a year and a half later, on August 23, 2019, Freeman was sentenced on the North Carolina state charges to a term of imprisonment of 50 to 70 months with credit for 547

days. The North Carolina judgment also ordered Freeman’s sentence “TO RUN CONCURRENT WITH ANY SENTENCE THE DEFENDANT MAY BE SERVING.” ECF No. 12-1 at 47. On appeal, the United States Court of Appeals for the Fourth Circuit found that Freeman received ineffective assistance of counsel at sentencing, vacated her federal sentence, and remanded for resentencing. On March 23, 2023, a Post Plea Agreement was reached between Freeman and the United States wherein the government agreed to recommend “a sentence of 110 months with credit for time already served.” On that same day, the district court resentenced Freeman to a 110-month term of imprisonment and recommended that “defendant receive credit

for time served in custody for relevant conduct associated with the offense of conviction beginning March 1, 2018.” ECF No. 12- 1 at 60. In her petition, Freeman argues that the Bureau of Prisons (“BOP”) is improperly calculating her term of imprisonment. Specifically, she maintains that the BOP is erroneously (1) denying her credit for time spent in state custody; and (2) denying her request for a nunc pro tunc designation. In his PF&R, Magistrate Judge Aboulhosn explained that petitioner’s claims were subject to dismissal for her failure to exhaust available administrative remedies before filing the

instant petition. In her objections, Freeman objects to the PF&R’s recommendation that her petition be dismissed for failure to properly exhaust, maintaining that she did exhaust her administrative remedies. See ECF No. 20 at 1-2. However, her petition contradicts this assertion as Freeman admits that her appeal to the Central Office was not complete when she filed suit. “As a general rule, in the absence of exceptional circumstances where the need for the remedy afforded by the writ of habeas corpus is apparent . . . courts require exhaustion of alternative remedies before a prisoner can seek habeas relief.” Timms v. Johns, 627 F.3d 525, 530-31 (4th Cir. 2010) (internal

quotations omitted); see also United States v. Wilson, 503 U.S. 329, 335 (1992) (“Federal regulations have afforded prisoners administrative review of the computation of their credits . . . and prisoners have been able to seek judicial review of these computations after exhausting their administrative remedies[.]”) (emphasis added). Section 2241 does not contain a statutory mandate that administrative remedies be exhausted, however, courts have judicially imposed such a requirement. See Jaworski v. Gutierrez, 509 F. Supp. 2d 573, 578 (N.D.W. Va. 2007) (“[T]he exhaustion requirement in habeas corpus actions arising under § 2241 . . . has no statutory mandate, but rather is judicially imposed.”); Taylor v. Lue, Civil Action No. 7:19CV486, 2020 WL

5807995, at *3 (W.D. Va. Sept. 29, 2020) (“Although § 2241 does not contain a statutory exhaustion requirement, courts require petitioners to exhaust their administrative remedies prior to seeking habeas review under § 2241.”). Courts within the Fourth Circuit have consistently required litigants to exhaust their alternative remedies before bringing Section 2241 claims. See Timms, 627 F.3d at 533 (dismissing habeas claim under § 2241 for failure to exhaust); McClung v. Shearin, No. 03-6952, 90 F. App’x 444, 445 (4th Cir. Feb. 6, 2004) (“Federal prisoners must exhaust their administrative remedies prior to filing § 2241 petitions.”). Requiring exhaustion promotes the “‘important

considerations of federal court efficiency and administration.’” Id. at 531 n.5 (quoting Moore v. United States, 875 F. Supp. 620, 624 (D. Neb. 1994)). Only in “‘exceptional circumstances’” should exhaustion be waived, id. at 530-31 (quoting Bowen v. Johnson, 306 U.S. 19, 27 (1939)), such as when the administrative remedy process would be futile. See Jaworski, 509 F. Supp. 2d at 578; see also Hairston v. Wilson, 1:13cv126(TSE/IDD), 2013 WL 12149685, at *2 (E.D. Va. Feb. 5, 2013) (“It is true that, in rare cases, § 2241 habeas petitioners have been excused from the exhaustion requirement if they can show that proceeding through the administrative remedy process undoubtedly would be an exercise in futility that would

serve no useful purpose.”) . Here, although petitioner maintains she did exhaust all available remedies prior to filing her petition, the BOP records and her own petition show otherwise.1 And her objections do not adequately explain why doing so would have been futile or suggest that exceptional circumstances exist here to excuse her failure to exhaust.

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Freeman v. Cutright, Counsel Stack Legal Research, https://law.counselstack.com/opinion/freeman-v-cutright-wvsd-2025.