Landis v. Federal Bureau of Prisons

CourtDistrict Court, District of Columbia
DecidedNovember 7, 2025
DocketCivil Action No. 2023-3635
StatusPublished

This text of Landis v. Federal Bureau of Prisons (Landis v. Federal Bureau of Prisons) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Landis v. Federal Bureau of Prisons, (D.D.C. 2025).

Opinion

faUNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

__________________________________________ : CARLTON THEODORE LANDIS, : : Plaintiff, : : v. : Civil Action No. 23-3635 (CKK) : FEDERAL BUREAU OF PRISONS, : : Defendant. : _________________________________________ :

MEMORANDUM OPINION

Over the years, Cartlton Theodore Landis (“plaintiff”) has been designated to several

Federal Bureau of Prisons (“BOP”) facilities, including seven penitentiaries (USPs Yazoo City,

Allenwood, Lewisburg, Thompson, Victorville, Coleman and McCreary) and one correctional

institution (FCI Petersburg). This civil action pertains to four aspects of plaintiff’s confinement.

Before the Court is Defendant’s Motion to Dismiss and Memorandum in Support (ECF

No. 15) and plaintiff’s Motion for Order (ECF No. 25). For the reasons discussed below, the

Court GRANTS the former and DENIES the latter.

I. BACKGROUND

A. Defendant’s Motion to Dismiss is Unopposed

Plaintiff filed his complaint (ECF No. 1, “Compl,”) on December 4, 2023.1 Defendant

filed its motion to dismiss and supporting memorandum (ECF No. 15, “Def.’s Mem.”) on

1 Plaintiff’s complaint is a preprinted form with a handwritten Statement of Claim. In this Memorandum Opinion, unless specified otherwise, the Court cites the handwritten statement and the paragraph numbers designated by plaintiff. 1 November 15, 2024. The Court issued an Order (ECF No. 16) on November 18, 2024, advising

plaintiff of his obligation to respond to the motion, and if he failed to do so, the Court would rule

on defendant’s motion without the benefit of his position. The Order set December 27, 2024, as

the deadline for plaintiff’s opposition. Plaintiff requested, and the Court granted, four extensions

of time by Minute Orders on December 31, 2024, January 23, 2025, April 7, 2025, and May 22,

2025. The latest deadline, July 31, 2025, has passed, and plaintiff neither filed a response to

defendant’s motion nor requested additional time to do so.

The Court’s ruling is based on plaintiff’s original complaint and the memorandum

supporting defendant’s motion to dismiss.

B. Plaintiff’s “Motion for Order” is Denied

Plaintiff filed his Motion for Order (ECF No. 25, “Pl.’s Mot.”) on August 25, 2025. He

represented that, on July 25, 2025, he mailed to the Clerk of Court “an amended complaint in

response to Defendant’s Motion to Dismiss.” Id. ¶ 2. He neglected to “put the case number on

the amended complaint,” id., and the Clerk of Court treated it as a complaint in a new civil

action. The Clerk of Court issued a deficiency notice in the new action on August 7, 2025,

directing plaintiff either to submit an application to proceed in forma pauperis or pay the filing

fee in full, and warning that his failure to comply would result in the administrative closure of

the case. Plaintiff did not respond, and the Clerk of Court administratively closed the case. See

Landis v. Fed. Bureau of Prisons, No. 25-cv-2593 (UNA) (D.D.C. Sept. 16, 2025).

“In order to correct the clerical error provoked by [p]laintiff’s inadvertence, [p]laintiff

respectfully requests that this Court file the complaint in Case No. 25-cv-02593-UNA as [his]

First Amended Complaint in this action.” Pl.’s Mot. ¶ 5.

A plaintiff may amend his complaint under the following conditions:

2 (1) Amending as a Matter of Course. A party may amend its pleading once as a matter of course no later than: (A) 21 days after serving it, or (B) if the pleading is one to which a responsive pleading is required, 21 days after service of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), whichever is earlier. (2) Other Amendments. In all other cases, a party may amend its pleading only with the opposing party’s written consent or the court’s leave. The court should freely give leave when justice so requires. FED. R. CIV. P. 15(a).

The decision to grant or deny leave to amend a complaint “is committed to a district

court’s discretion.” Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996). In determining

whether “justice so requires,” the Court considers factors including “undue delay, bad faith or

dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments

previously allowed, undue prejudice to the opposing party by virtue of allowance of the

amendment, [and] futility of amendment[.]” Atchinson v. District of Columbia, 73 F.3d 418,

425-26 (D.C. Cir. 1996) (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)); see Richardson v.

United States, , 193 F.3d 545, 548-49 (D.C. Cir. 1999) (citing Foman, 371 U.S. at 182). The

Court “may deny a motion to amend a complaint as futile . . . if the proposed claim would not

survive a motion to dismiss.” James Madison Ltd. v. Ludwig, 82 F.3d 1085, 1099 (D.C. Cir.

1996) (citing Foman, 371 U.S. at 181–82). Consequently, “review for futility ‘is, for practical

purposes, identical to review of a Rule 12(b)(6)’ motion to dismiss.” Driscoll v. George

Washington Univ., 42 F. Supp. 3d 52, 57 (D.D.C. 2012) (quoting In re Interbank Funding Corp.

Sec. Litig., 629 F.3d 213, 215-16 (D.C. Cir. 2010)).

The time for plaintiff to have amended his complaint as a matter of course under Rule

15(a)(1) has passed, and at this late date, he may amend only with defendant’s consent or by the

3 Court’s leave. The Court presumes that defendant opposes the motion, and the Court denies

leave to amend. Based on the Court’s review of the proposed amended complaint, which is

substantially similar to the original complaint, amendment is futile.

II. PLANTIFF’S FACTUAL ALLEGATIONS

A. First Step Act Time Credits

In 2003, plaintiff was convicted in the United States District Court for the Eastern

District of North Carolina of possession of cocaine with intent to distribute and, in violation of

18 U.S.C. § 924(c), possession of a firearm in furtherance of a drug trafficking crime. See

Compl. ¶ 1. That court imposed a 12-year term of imprisonment, and in 2012, plaintiff began a

five-year term of supervised release. See id. ¶¶ 1-2. Plaintiff violated the terms of his supervised

release when charged with and convicted of unarmed bank robbery in 2013. See id. ¶ 3. Upon

completion of a five-year term for the supervised release violation, plaintiff began to serve a 14-

year term of imprisonment for bank robbery in 2018. See id. ¶ 4.

Plaintiff claims he “already served all of his prison term for his conviction for possession

of a firearm in furtherance of a drug trafficking crime,” id. ¶ 11, and considers it “a prior

conviction,” id., which does not disqualify him from earning time credits under the First Step

Act. See generally id. ¶¶ 7-12. BOP, however, deems plaintiff ineligible for FSA time credits,

see id. ¶¶ 7, 12, in light of the conviction under 18 U.S.C. § 924(c), see id. ¶¶ 8, 56, and plaintiff

demands judicial review of BOP’s determination, see id. ¶ 56.

4 B.

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