Marshall DeWayne Williams v. Pamela Bondi, United States Attorney, et al.

W.D. Pennsylvania

Marshall DeWayne Williams v. Pamela Bondi, United States Attorney, et al.

DecidedOctober 24, 2025

Docket1:25-cv-00126

StatusUnknown

This text of Marshall DeWayne Williams v. Pamela Bondi, United States Attorney, et al. (Marshall DeWayne Williams v. Pamela Bondi, United States Attorney, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marshall DeWayne Williams v. Pamela Bondi, United States Attorney, et al., (W.D. Pa. 2025).

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IN THE UNITED STATES DISTRICT COURT . FOR THE WESTERN DISTRICT OF PENNSYLVANIA MARSHALL DEWAYNE WILLIAMS, ) Petitioner, ) Vv. Case No. 1:25-cv-126-SPB-RAL PAMELA BONDI, United States Attorney, ef al., ) Respondents.

MEMORANDUM ORDER REGARDING APPEAL AT ECE NO. [5] Petitioner Marshall DeWayne Williams commenced this civil action on May 19, 2025, seeking a writ of habeas corpus pursuant to 28 U.S.C. §2241. The case has been referred to Chief U.S. Magistrate Judge Richard A. Lanzillo for a Report and Recommendation, in accordance with the Magistrate Judge's Act, 28 U.S.C. §636(b)(1) and Local Civil Rule 72. On June 5, 2025, Williams filed an “Emergency Motion for Temporary Restraining Orde (“T.R.O.”), or Preliminary Injunction Directing Respondent Employees Not to ‘Throw Petitioner’s Legal and Personal Property In the Trash’ on July 13, 2025.” ECF No. 2. Williams requested that the emergency court order be sent to employees “B. Brantley, R&D Officer” at F.C. Bennettsville and “Ms. Allen, R&D Supervisor” at F.C.1. McKean. Judge Lanzillo denied Williams’ motion in a text order dated August 5, 2025. The text order explained that “[t]he Court has no authority to issue an order to prison officials directing them as to how to handle Petitioner's private property in a habeas corpus action pursuant to 28 U.S.C. Section 2241.” ECF No. 3. One week later, on August 12, 2025, Judge Lanzillo issued an order administratively closing the case pending Plaintiff's payment of the $5.00 filing fee or

submission of a motion to proceed IFP by September 5. 2025. ECF No. 4. Williams was later given an extension of time, and his IFP motion is now due on or before November 7, 2025. ECF No. 7. In the meantime, Williams filed an appeal of Judge Lanzillo’s August 5, 2025 order denying his motion for emergency injunctive relief. ECF No. 5. In his appeal, Williams contends that Chief Judge Lanzillo erred by improperly denying the Court’s jurisdiction to issue the requested relief. While recognizing that federal courts have limited jurisdiction, Williams nevertheless contends that the courts have “many types of jurisdiction -- including ‘plenary,’” and the courts “must effect their duty to oversee and supervise the case to ensure justice.” Id. Pursuant to 28 U.S.C. §636(b)(1)(A), a magistrate judge may hear and determine most non-dispositive pretrial matters. A district judge may reconsider these determinations on appeal if the decision was clearly erroneous or contrary to law. 28 U.S.C. § 636(b)(1)(A); NLRB. v. Frazier, 966 F.2d 812, 816 (3d Cir. 1992). Here, the Court perceives no basis for disturbing Judge Lanzillo’s ruling. With respect to federal prisoners like Williams, 28 U.S.C. § 2241 confers habeas jurisdiction over an inmate's challenge to the execution — as opposed to the validity — of his sentence. Cardona v. Bledsoe, 681 F.3d 533,535 (3d Cir. 2012). Two types of claims may ordinarily be litigated in a § 2241 proceeding. First, a prisoner may challenge conduct undertaken by the Federal Bureau of Prisons (the “BOP”) that affects the duration of his custody. For example, a prisoner can challenge the BOP's computation of his federal sentence, see, e.g., Barden v. Keohane, 921 F.2d 476, 478-79 (3d Cir. 1990), or the constitutionality of a BOP disciplinary action that resulted in the loss of good conduct sentencing credits, Queen v. Miner, 530 F.3d 253, 254 n.2 (3d Cir. 2008). Secondly, a prisoner can challenge BOP conduct that “‘conflict[s] with express statements in the

applicable sentencing judgment.” Cardona, 681 F.3d at 536; Woodall v. Federal Bureau of Prisons, 432 F.3d 235, 243 (3d Cir. 2005). As the party seeking preliminary injunctive relief, Williams has the burden of demonstrating: (1) a reasonable probability of success on the merits; (2) irreparable harm if the injunction is denied; (3) that the issuance of an injunction will not result in greater harm to the non-moving party; and (4) that the public interest would best be served by granting the injunction. Council of Alternative Political Parties v. Hooks, 121 F.3d 876, 879 (3d Cir. 1997); Opticians Ass'n of America v. Independent Opticians of America, 920 F.2d 187, 191-92 (3d Cir. 1990). To state a basis for injunctive relief, Williams’ motion must allege facts and claims that are connected to those raised in his §2241 petition. See Ball v. Famiglio, 396 F. App’x 836, 837 (3d Cir. 2010) (per curiam); James v. Varano, No. 1:14-CV-01951, 2017 WL 895569, at *3 (M.D. Pa. Mar. 7, 2017) (stating that “there must be a connection between the underlying complaint and the relief requested in the motion for a preliminary injunction”). Moreover, a request for injunctive relief in the prison context “must always be viewed with great caution because ‘judicial restraint is especially called for in dealing with the complex and intractable problems of prison administration.’” Goff v. Harper, 60 F.3d 518, 520 (8th Cir. 1995) (quoting Rogers v. Scurr, 676 F.2d 1211, 1214 (8th Cir. 1982)). “Preliminary injunctive relief is not a tool for prisoners to use to regulate ‘in every way, every day, the terms and conditions of plaintiff's confinement simply because they are in court and regardless of the relation of the activity desired to be stopped with the claim in the complaint.’” Stile v. Fed. Bureau of Prisons, CIV. NO. 16-3832, 2017 WL 2656646, at *4 (D.N.J. June 19, 2017) (quoting Muhammad y. Director of Corrections, No. CIV 8-07-0375 GEB GGH P, 2009 WL 161075, at *1 (E.D. Ca. Jan. 22, 2009)). Thus, where a plaintiff requests an injunction that would require the

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IN THE UNITED STATES DISTRICT COURT . FOR THE WESTERN DISTRICT OF PENNSYLVANIA MARSHALL DEWAYNE WILLIAMS, ) Petitioner, ) Vv. Case No. 1:25-cv-126-SPB-RAL PAMELA BONDI, United States Attorney, ef al., ) Respondents.

MEMORANDUM ORDER REGARDING APPEAL AT ECE NO. [5] Petitioner Marshall DeWayne Williams commenced this civil action on May 19, 2025, seeking a writ of habeas corpus pursuant to 28 U.S.C. §2241. The case has been referred to Chief U.S. Magistrate Judge Richard A. Lanzillo for a Report and Recommendation, in accordance with the Magistrate Judge's Act, 28 U.S.C. §636(b)(1) and Local Civil Rule 72. On June 5, 2025, Williams filed an “Emergency Motion for Temporary Restraining Orde (“T.R.O.”), or Preliminary Injunction Directing Respondent Employees Not to ‘Throw Petitioner’s Legal and Personal Property In the Trash’ on July 13, 2025.” ECF No. 2. Williams requested that the emergency court order be sent to employees “B. Brantley, R&D Officer” at F.C. Bennettsville and “Ms. Allen, R&D Supervisor” at F.C.1. McKean. Judge Lanzillo denied Williams’ motion in a text order dated August 5, 2025. The text order explained that “[t]he Court has no authority to issue an order to prison officials directing them as to how to handle Petitioner's private property in a habeas corpus action pursuant to 28 U.S.C. Section 2241.” ECF No. 3. One week later, on August 12, 2025, Judge Lanzillo issued an order administratively closing the case pending Plaintiff's payment of the $5.00 filing fee or

submission of a motion to proceed IFP by September 5. 2025. ECF No. 4. Williams was later given an extension of time, and his IFP motion is now due on or before November 7, 2025. ECF No. 7. In the meantime, Williams filed an appeal of Judge Lanzillo’s August 5, 2025 order denying his motion for emergency injunctive relief. ECF No. 5. In his appeal, Williams contends that Chief Judge Lanzillo erred by improperly denying the Court’s jurisdiction to issue the requested relief. While recognizing that federal courts have limited jurisdiction, Williams nevertheless contends that the courts have “many types of jurisdiction -- including ‘plenary,’” and the courts “must effect their duty to oversee and supervise the case to ensure justice.” Id. Pursuant to 28 U.S.C. §636(b)(1)(A), a magistrate judge may hear and determine most non-dispositive pretrial matters. A district judge may reconsider these determinations on appeal if the decision was clearly erroneous or contrary to law. 28 U.S.C. § 636(b)(1)(A); NLRB. v. Frazier, 966 F.2d 812, 816 (3d Cir. 1992). Here, the Court perceives no basis for disturbing Judge Lanzillo’s ruling. With respect to federal prisoners like Williams, 28 U.S.C. § 2241 confers habeas jurisdiction over an inmate's challenge to the execution — as opposed to the validity — of his sentence. Cardona v. Bledsoe, 681 F.3d 533,535 (3d Cir. 2012). Two types of claims may ordinarily be litigated in a § 2241 proceeding. First, a prisoner may challenge conduct undertaken by the Federal Bureau of Prisons (the “BOP”) that affects the duration of his custody. For example, a prisoner can challenge the BOP's computation of his federal sentence, see, e.g., Barden v. Keohane, 921 F.2d 476, 478-79 (3d Cir. 1990), or the constitutionality of a BOP disciplinary action that resulted in the loss of good conduct sentencing credits, Queen v. Miner, 530 F.3d 253, 254 n.2 (3d Cir. 2008). Secondly, a prisoner can challenge BOP conduct that “‘conflict[s] with express statements in the

applicable sentencing judgment.” Cardona, 681 F.3d at 536; Woodall v. Federal Bureau of Prisons, 432 F.3d 235, 243 (3d Cir. 2005). As the party seeking preliminary injunctive relief, Williams has the burden of demonstrating: (1) a reasonable probability of success on the merits; (2) irreparable harm if the injunction is denied; (3) that the issuance of an injunction will not result in greater harm to the non-moving party; and (4) that the public interest would best be served by granting the injunction. Council of Alternative Political Parties v. Hooks, 121 F.3d 876, 879 (3d Cir. 1997); Opticians Ass'n of America v. Independent Opticians of America, 920 F.2d 187, 191-92 (3d Cir. 1990). To state a basis for injunctive relief, Williams’ motion must allege facts and claims that are connected to those raised in his §2241 petition. See Ball v. Famiglio, 396 F. App’x 836, 837 (3d Cir. 2010) (per curiam); James v. Varano, No. 1:14-CV-01951, 2017 WL 895569, at *3 (M.D. Pa. Mar. 7, 2017) (stating that “there must be a connection between the underlying complaint and the relief requested in the motion for a preliminary injunction”). Moreover, a request for injunctive relief in the prison context “must always be viewed with great caution because ‘judicial restraint is especially called for in dealing with the complex and intractable problems of prison administration.’” Goff v. Harper, 60 F.3d 518, 520 (8th Cir. 1995) (quoting Rogers v. Scurr, 676 F.2d 1211, 1214 (8th Cir. 1982)). “Preliminary injunctive relief is not a tool for prisoners to use to regulate ‘in every way, every day, the terms and conditions of plaintiff's confinement simply because they are in court and regardless of the relation of the activity desired to be stopped with the claim in the complaint.’” Stile v. Fed. Bureau of Prisons, CIV. NO. 16-3832, 2017 WL 2656646, at *4 (D.N.J. June 19, 2017) (quoting Muhammad y. Director of Corrections, No. CIV 8-07-0375 GEB GGH P, 2009 WL 161075, at *1 (E.D. Ca. Jan. 22, 2009)). Thus, where a plaintiff requests an injunction that would require the

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