Matthew L. Staszak v. Chad Garrett

• Court: District Court, E.D. Arkansas
• Decided: June 16, 2026
• Docket: 2:23-cv-00137
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION

MATTHEW L. STASZAK PETITIONER Reg #24227-171

v. Case No. 2:23-cv-00137-KGB

CHAD GARRETT RESPONDENT

ORDER Before the Court is the Recommended Disposition (“Recommendation”) submitted by United States Magistrate Patricia S. Harris (Dkt. No. 15). Pro se petitioner Matthew L. Staszak filed objections to the Recommendation (Dkt. No. 16). After conducting a de novo review of the record, the Court determines that Staszak’s objections break no new legal ground. With respect to Staszak’s objection to his case being heard by a Magistrate Judge, the Court notes that Magistrate Judges are authorized by the Federal Magistrate Judges Act to hear and issue recommendations on petitions for a writ habeas corpus. Davis v. Rardin, Case No. 22-cv-02854-JRT-JLM, 2023 WL 2503499, at 3 (D. Minn. Mar. 14, 2023), appeal dismissed, Case No. 23-1655, 2023 WL 6465879 (8th Cir. Apr. 20, 2023) (citing 28 U.S.C. § 636(b)(1)(B)). Consent is required only where a Magistrate Judge issues a final judgment, which is not the case here. Id. With respect to the substantive arguments raised in Staszak’s petition and the subsequent briefing, the Court notes that at least two circuits have upheld the validity of the Federal Bureau of Prisons’ practice of aggregating concurrent and consecutive sentences for purposes of determining eligibility for time credits under the First Step Act of 2018, 18 U.S.C. § 3632, since the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024). See Colotti v. Peters, Case No. 25-1191, 2025 WL 1321386, at *2 (3d Cir. May 7, 2025); Giovinco v. Pullen, 118 F.4th 527, 530–33 (2d Cir. 2024), cert. denied sub nom. Giovinco v. Flowers, Case No. 24-6827, 2025 WL 1151338 (U.S. Apr. 21, 2025). As such, the Court determines that the Eighth Circuit Court of Appeals’ unpublished per curiam decision in Sok v. Eischen remains an accurate summary of the state of the law on this issue in the Eighth Circuit. Case No. 23-1025, 2023 WL 5282709 (8th Cir. Aug. 17, 2023); see also Clinkenbeard v. Murdock, Case No. 24-3127, 2025 WL 926451 (8th Cir. Mar. 27, 2025) (applying the same analysis) The Court thus overrules Staszak’s objections (Dkt. No. 16), and the Court adopts the Recommendation in its entirety as this Court’s findings in all respects (Dkt. No. 15). Staszak’s petition for a writ of habeas corpus is denied with prejudice (Dkt. No. 1). Judgment will be entered accordingly. It is so ordered this 16th day of June, 2026. Ku sta A. par istine G. Baker Chief United States District Judge