(HC)Heath v. Warden at FCI Mendota

CourtDistrict Court, E.D. California
DecidedAugust 21, 2023
Docket1:22-cv-01529
StatusUnknown

This text of (HC)Heath v. Warden at FCI Mendota ((HC)Heath v. Warden at FCI Mendota) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(HC)Heath v. Warden at FCI Mendota, (E.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 RANDALL HEATH, No. 1:22-cv-01529-HBK (HC) 12 Petitioner, OPINION AND ORDER GRANTING RESPONDENT’S MOTION TO DISMISS1 13 v. (Doc. No. 8) 14 WARDEN, FCI MENDOTA, 15 Respondent. 16 17 Petitioner Randall Heath (Petitioner or Heath), a federal inmate, initiated this action on 18 November 28, 2022 by filing a pro se petition for writ of habeas corpus under 28 U.S.C. § 2241, 19 while he was incarcerated at Federal Correctional Institution (FCI) Mendota, located in Fresno 20 County, California, which is within the venue and jurisdiction of this Court. (Doc. No. 1, 21 Petition). The Petition raises two claims: (1) the Bureau of Prisons (BOP) violated the First Step 22 Act of 2018 because it refuses to permit inmates to earn and apply times credits toward their 23 sentences if they decline to participate in evidence-based recidivism reduction programs or 24 productive activities recommended by BOP staff; and (2) the BOP failed to calculated 25 Petitioner’s sentence accurately because his current sentence calculation does not include the 26 time credits he earned for participating in classes of his choosing. (Doc. No. 1 at 6, 9); see 18 27 1 Both parties have consented to the jurisdiction of a magistrate judge, in accordance with 28 U.S.C. § 28 636(c)(1). (Doc. No. 7). 1 U.S.C. § 3632(d)(4)(A), (C) (providing that FTCs earned from completion of evidence-based 2 recidivism reduction programs (EBBRs) and productive activities (PAs) shall be applied toward 3 time in prerelease custody or supervised release). Petitioner provides no specific number of FTCs 4 to which he is entitled; rather, he asks the Court to “enjoin the BOP to award [F]TCs for “any 5 EBRR program or [PA] activities [he] participates in as per the First Step Act of 2018” and 6 “enjoin the BOP to change its policy concerning the same.” (Doc. No. 1 at 7). Petitioner admits 7 he did not exhaust his administrative remedies because he is challenging a policy, so exhaustion 8 is futile. (Id. at 7). 9 In response, Respondent filed a Motion to Dismiss with Appendix on February 10, 2023. 10 (Doc. Nos. 8, 8-1). Respondent seeks dismissal of Petition because this Court lacks statutory 11 authority under § 2241 to compel discretionary action via declaratory and advisory opinions, and 12 because Petitioner failed to exhaust his administrative remedies for both grounds. (Doc. No. 8 at 13 2). Moreover, Respondent argues “Petitioner’s demand that this Court legislate and manage 14 BOP’s discretionary authority generally, and particularly for Petitioner, is without legal merit.” 15 (Id.). Petitioner filed neither a response to the motion nor a request for an extension of time to 16 respond, and the time for doing so has expired. (See Doc. No. 4 at ¶ 4, advising Petitioner that he 17 has twenty-one (21) days to file a response if Respondent files a motion to dismiss). The Court 18 grants Respondent’s Motion to Dismiss. 19 I. BACKGROUND 20 A. Procedural History 21 Heath is serving a 156-month sentence after pleading guilty to federal crimes including 22 conspiracy to distribute fentanyl and marijuana in violation of 21 U.S.C. §§ 841(a)(1) and 846, 23 and conspiracy to commit money laundering promotion and concealment in violation of 18 24 U.S.C. § 1956(a)(1)(A)(i) and 1956(a)(1)(B)(i), imposed by the United States District Court for 25 the District of Utah (D-UT) in 2019. See United States v. Waldron et al., 2:18-cr-00031-TC-2, 26 Crim. Doc. Nos. 43, 454, 456 (D. Ut.)2; Doc. No. 8-1. Heath is incarcerated at FCI Mendota. 27 2 The undersigned cites to the record in Petitioner’s underlying D-UT criminal case as “Crim. Doc. No. 28 _.”. 1 Heath’s current projected release date, including adjustments for possible good time credits is 2 July 13, 2029. (Doc. No. 8-1 at 3, 11-12). He has earned 35 FTCs toward RRC or home 3 confinement and 365 FTCs toward early supervised release; however, he is ineligible to apply 4 time credits as he is scored at a medium recidivism risk level and has an unresolved pending 5 charge. (Id. at 9, 21). 6 II. APPLICABLE LAW AND ANALYSIS 7 Under Rule 4, if a petition is not dismissed at screening, the judge “must order the 8 respondent to file an answer, motion, or other response” to the petition. R. Governing 2254 Cases 9 4. The Advisory Committee Notes to Rule 4 state that “the judge may want to authorize the 10 respondent to make a motion to dismiss based upon information furnished by respondent.” A 11 motion to dismiss a petition for writ of habeas corpus is construed as a request for the court to 12 dismiss under Rule 4 of the Rules Governing Section 2254 Cases. O’Bremski v. Maass, 915 F.2d 13 418, 420 (9th Cir. 1990). Under Rule 4, a district court must dismiss a habeas petition if it 14 “plainly appears” that the petitioner is not entitled to relief. See Valdez v. Montgomery, 918 F.3d 15 687, 693 (9th Cir. 2019); Boyd v. Thompson, 147 F.3d 1124, 1127 (9th Cir. 1998). 16 A. Failure to Exhaust Administrative Remedies 17 “Federal prisoners [generally] are required to exhaust their federal administrative 18 remedies prior to bringing a petition for a writ of habeas corpus in federal court.” Martinez v. 19 Roberts, 804 F.2d 570, 571 (9th Cir. 1986); see also Ward v. Chavez, 678 F.3d 1042 (9th Cir. 20 2012). However, the requirement that federal prisoners exhaust administrative remedies before 21 filing a habeas corpus petition was judicially created; it is not a statutory requirement. Brown v. 22 Rison, 895 F.2d 533, 535 (9th Cir. 1990), overruled on other grounds by Reno v. Koray, 515 U.S. 23 50, 54-55 (1995). Because exhaustion is not required by statute, it is not jurisdictional. Id. (citing 24 Morrison-Knudsen Co., Inc. v. CHG Int’l, Inc., 811 F.2d 1209, 1223 (9th Cir. 1987)). If 25 petitioner has not properly exhausted his claims, the district court, in its discretion, may 26 “determine whether to excuse the faulty exhaustion and reach the merits or require the petitioner 27 to exhaust his administrative remedies before proceeding in court.” Id. 28 Requiring a petitioner to exhaust administrative remedies (1) aids judicial review “by 1 allowing the appropriate development of a factual record in an expert forum,” (2) conserves “the 2 court's time because of the possibility that the relief applied for may be granted at the 3 administrative level,” and (3) allows “the administrative agency an opportunity to correct errors 4 occurring in the course of administrative proceedings.” Ruviwat v. Smith, 701 F.2d 844, 845 (9th 5 Cir. 1983) (per curiam). Dismissal is appropriate when a federal prisoner has not exhausted the 6 administrative remedies made available by the BOP. See Quinonez v. McGrew, 649 F. App'x 475 7 (9th Cir.

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Bluebook (online)
(HC)Heath v. Warden at FCI Mendota, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hcheath-v-warden-at-fci-mendota-caed-2023.