Lykens v. Peters

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 4, 2025
Docket4:24-cv-01385
StatusUnknown

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

Bluebook
Lykens v. Peters, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

SCOTT LYKENS,

Plaintiff, CIVIL ACTION NO. 4:24-cv-01385

v. (SAPORITO, J.)

COLETTE S. PETERS, et al.,

Defendants.

MEMORANDUM Now before the court is a report and recommendation of Chief United States Magistrate Judge Daryl F. Bloom, in which he recommends that this action be dismissed for lack of subject matter jurisdiction, and the plaintiff’s motion to remand this action to state court be denied as moot. Doc. 14. This action was originally commenced by the plaintiff in state court. Doc. 1-2. It was removed to this court by the United States on August 16, 2024. Doc. 1. The plaintiff has filed a motion to remand the action back to state court, which is fully briefed and ripe for decision. Doc. 3; Doc. 6; Doc. 9; Doc. 11. Meanwhile, the United States has filed a motion to dismiss the action for lack of subject matter jurisdiction or, in the alternative, for failure to state a claim upon which relief can be granted. Doc. 8. The motion to dismiss is likewise fully briefed and ripe for

decision. Doc. 10; Doc. 12; Doc. 13. On November 27, 2024, the magistrate judge entered his report recommending that the motion to dismiss be granted and the motion to

remand be denied. The plaintiff has filed objections to the report and recommendation. We will adopt the magistrate judge’s recommendations, but for different reasons than those advanced in his report.

I. STANDARD OF REVIEW “When objections to a report and recommendation have been filed, the court must make a determination of those portions of the

report to which specific objections are made.” , 54 F. Supp. 3d 339, 342 (M.D. Pa. 2014). “When conducting a review, the court may accept, reject, or modify, in whole or in part, the factual

findings or legal conclusions of the magistrate judge.” , 607 F. Supp. 3d 522, 529 (M.D. Pa. 2022); 28 U.S.C. § 636(b)(1); M.D. Pa. L.R. 72.3; , 54 F. Supp. 3d at 342. A

determination, however, is not required if the objections are not specific. , 749 F.2d 5, 6–7 (3d Cir. 1984) (per curiam); , 607 F. Supp. 3d at 529. At a minimum, uncontested portions of the report and recommendation and general objections must be

reviewed for clear error or manifest injustice. , 607 F. Supp. 3d at 529–30; , 54 F. Supp. 3d at 341–42; , 990 F. Supp. 375, 376–77 (M.D. Pa. 1998).

II. BACKGROUND In April 2022, Lykens pleaded guilty to federal tax violations and was sentenced to serve a term of 15 months of imprisonment. On May 20, 2022, Lykens self-surrendered and was taken into custody of the United

States Bureau of Prisons (“BOP”) to serve his sentence. On March 14, 2023, he was released from BOP custody.

Lykens, however, alleges that the named defendants1 and some number of unidentified BOP employees2 willfully miscalculated his accrual of FSA time credits.3 By Lykens’s own calculations, he was

1 The named defendants are: (1) Colette S. Peters, Director of the BOP; (2) James C. Petrucci, Northeast Regional Director of the BOP; and (3) Stephen Spaulding, Chief Executive Officer of USP Lewisburg, a BOP correctional facility. 2 The complaint named “John Does 1 through 20” as defendants, but it did not describe any of these fictitious defendants with any particularity. 3 In his papers, the plaintiff has referred to these time credits as “earned time credits.” The First Step Act itself simply uses the term “time credits.” 18 U.S.C. § 3632(d)(4). In its implementing regulations, the entitled to 135 days of FSA time credits, but BOP officials awarded him

only 90 days of FSA time credits. As a result, he alleges that he was unlawfully imprisoned for 45 days after the date when he should have been released from BOP custody.

On July 1, 2024, Lykens filed his complaint in state court, asserting 45 counts of the state-law tort of false imprisonment—one count for each day of allegedly unlawful incarceration—against the defendants in their

personal capacities. On August 16, 2024, the United States removed the action to this court, asserting that, under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 1346(b) and 28 U.S.C. § 2671 , it was the

only proper defendant in any civil action involving the acts or omissions of a government employee. Lykens moved to remand the case to state court, arguing that the United States lacked standing to remove the

action, and that the notice of removal was procedurally defective.

BOP has dubbed them “FSA time credits.” 28 C.F.R. § 523.40 For the sake of clarity, we have generally adopted this label, “FSA time credits,” to distinguish them from other sorts of “time credits” awarded in the federal prison system. , 28 C.F.R. § 523.1 (addressing “statutory good time credit” and “extra good time credit” awarded to prisoners sentenced for offenses committed before November 1, 1987); § 523.20 (addressing “good conduct time credit” awarded pursuant to 18 U.S.C. § 3624(b)). On September 9, 2024, the United States filed a notice of

substitution, together with a certification that each of the three named defendants was a federal employee acting within the scope of his or her officer or employment with the federal government at the time of the

incident out of which the suit arose. 28 U.S.C. § 2679(d)(2); 28 C.F.R. § 15.4. As a consequence, the United States was automatically substituted in place of the three named defendants and the tort action

automatically converted into an FTCA action against the United States. , 522 F.3d 413, 416 (D.C. Cir. 2008). The United States then moved that same day to dismiss the action

for lack of subject matter jurisdiction or, in the alternative, for failure to state a claim. The United States advanced several alternative grounds for dismissal: (1) the plaintiff had failed to exhaust administrative

remedies by filing an administrative claim with the agency within two years after the incident giving rise to his tort claims, as required by 28 U.S.C. § 2401(d); (2) the plaintiff’s false imprisonment claims were

expressly barred by the terms of 28 U.S.C. § 2680(h); (3) to the extent the plaintiff’s over-detention claims could be construed as negligence claims, there was no state-law private party analogue; and (4) because the challenged sentence computation was never invalidated, the plaintiff’s

claims were barred by the favorable termination rule set forth in ,

Related

McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Grupo Dataflux v. Atlas Global Group, L. P.
541 U.S. 567 (Supreme Court, 2004)
Millbrook v. United States
133 S. Ct. 1441 (Supreme Court, 2013)
Lightfoot v. United States
564 F.3d 625 (Third Circuit, 2009)
Cruz v. Chater
990 F. Supp. 375 (M.D. Pennsylvania, 1998)
Sheppard v. United States
537 F. Supp. 2d 785 (D. Maryland, 2008)
D'ANGIO v. Borough of Nescopeck
34 F. Supp. 2d 256 (M.D. Pennsylvania, 1999)
Rendon v. United States
91 F. Supp. 2d 817 (E.D. Pennsylvania, 2000)
Thompson v. Smeal
54 F. Supp. 3d 339 (M.D. Pennsylvania, 2014)
McGowan v. United States
825 F.3d 118 (Second Circuit, 2016)
Celestial Community Development Corp. v. City of Philadelphia
901 F. Supp. 2d 566 (E.D. Pennsylvania, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Lykens v. Peters, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lykens-v-peters-pamd-2025.