Mora v. Rosalez

CourtDistrict Court, W.D. Texas
DecidedApril 5, 2023
Docket1:22-cv-01156
StatusUnknown

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

Bluebook
Mora v. Rosalez, (W.D. Tex. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

WILIBALDO MORA, § Petitioner § § 1:22-CV-01156-LY-SH v. § § WARDEN FNU ROSALEZ, § Respondent

REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

TO: THE HONORABLE LEE YEAKEL UNITED STATES DISTRICT JUDGE Before the Court is Petitioner Wilibaldo Mora’s Petition for Writ of Habeas Corpus Under 28 U.S.C. § 2241, filed November 7, 2022 (Dkt. 1), and the Government’s Response to the Petition and Motion to Dismiss, filed February 21, 2023 (Dkt. 9). The District Court referred the case to this Magistrate Judge pursuant to 28 U.S.C. § 636(b), Federal Rule of Civil Procedure 72, Rule 1 of Appendix C of the Local Rules of the United States District Court for the Western District of Texas, and the Court Docket Management Standing Order for United States District Judge Lee Yeakel. Dkt. 2. I. Background On June 15, 2018, the District Court entered judgment finding Petitioner Wilibaldo Mora guilty of conspiracy to possess with intent to distribute 5 kilograms or more of a controlled substance containing a detectable amount of cocaine, in violation of 21 U.S.C. § 846, and sentenced him to 300 months’ imprisonment, a five-year term of supervised release, a $2,000 fine, and forfeiture of $429,000. United States v. Mora, 2:16-CR-01115(5)-AM, Dkt. 1105 (W.D. Tex. June 15, 2018). Petitioner is incarcerated at the Federal Correctional Institute in Bastrop, Texas. Dkt. 1 at 1. In this Petition for Habeas Corpus under 28 U.S.C. § 2241, Petitioner argues that the Bureau of Prisons (“BOP”) has not properly calculated his earned time credits under the First Step Act (“FSA”). Petitioner asks the Court to order the BOP to apply those credits to his sentence. Petitioner alleges that he requested information about his time credits and received an “FSA Time Credit Assessment” form on October 9, 2022. Dkt. 1 at 3. The form shows that the BOP

counted 390 programming days towards his time credits and disallowed 996 days. Id. at 11. Petitioner states that these days were disallowed because the BOP Department of Psychology marked him as incomplete for an assessment, but contends that he was unaware an assessment was needed or incomplete. Id. at 4-5. As a result, Petitioner alleges that he has been wrongfully denied 498 days of earned credits towards release or home confinement. Id. at 3. He also alleges that the BOP violated the FSA by failing to complete his assessment by the January 15, 2020 deadline. In its Response and Motion to Dismiss, the Government argues that the Court should dismiss the Petition because (1) Petitioner failed to exhaust his administrative remedies, and (2) the Petition is moot because the BOP has updated Petitioner’s time credit calculation and Petitioner has not

plausibly alleged any further errors in the calculation. Petitioner did not file a response to the motion. Because Petitioner has failed to exhaust his administrative remedies, the Court need not address the Government’s alternative argument for dismissal. II. Legal Standards A. Section 2241 A petitioner may seek habeas relief under 28 U.S.C. § 2241(c)(3) if he is “in custody in violation of the Constitution or laws or treaties of the United States.” A prisoner bringing a § 2241 petition is limited to attacking “the manner in which a sentence is carried out or the prison authorities’ determination of its duration, and must be filed in the same district where the prisoner is incarcerated.” Pack v. Yusuff, 218 F.3d 448, 451 (5th Cir. 2000). The Attorney General, through the BOP, is responsible for administering a district court’s sentence. United States v. Wilson, 503 U.S. 329, 335 (1992). The BOP, not the district court, has the statutory authority to decide “where a federal sentence will be served, when it begins, and, in certain respects, how long it will last.” United States v. Aparicio, 963 F.3d 470, 478 (5th Cir. 2020) (citation omitted); see also United States v. Dowling, 962 F.2d 390, 393 (5th Cir. 1992) (stating

that “credit awards are to be made by the Attorney General, through the Bureau of Prisons, after sentencing”). Therefore, “[t]he BOP, not the district court, is empowered to calculate 18 U.S.C. § 3585(b) credits after the prisoner begins his sentence.” Aparicio, 963 F.3d at 478. Prisoners are afforded administrative review of their credit computation and may seek judicial review of the computation after exhausting administrative remedies with the BOP. Id. A petitioner must exhaust his administrative remedies through the BOP before filing a § 2241 petition. Gallegos-Hernandez v. United States, 688 F.3d 190, 194 (5th Cir. 2012). But failure to exhaust is not a jurisdictional requirement. See United States v. Franco, 973 F.3d 465, 468 (5th Cir. 2020). Exceptions to the exhaustion requirement may be made “where the available administrative

remedies either are unavailable or wholly inappropriate to the relief sought, or where the attempt to exhaust such remedies would itself be a patently futile course of action.” Gallegos-Hernandez, 688 F.3d at 194 (quoting Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994)). Exceptions may be made only in “extraordinary circumstances,” and the petitioner “bears the burden of demonstrating the futility of administrative review.” Fuller, 11 F.3d at 62. B. BOP Administrative Remedy Program The BOP Administrative Remedy Program provides a process “to allow an inmate to seek formal review of an issue relating to any aspect of his/her own confinement.” 28 C.F.R. § 542.10. A prisoner first must attempt to informally resolve the complaint with staff. § 542.13(a). If informal attempts are unsuccessful, the prisoner must submit a Request for Administrative Remedy to the Warden. § 542.14. If the prisoner is not satisfied with the Warden’s response, he may appeal to the Regional Director, then to the Office of General Counsel. § 542.15. Courts have found that “the BOP Administrative Remedy Program is an adequate ‘means through which allegedly unconstitutional actions . . . can be brought to the attention of the BOP and prevented from recurring.’” Silva v. United States, 45 F.4th 1134, 1141 (10th Cir. 2022) (quoting Corr. Servs.

Corp. v. Malesko, 534 U.S. 61, 74 (2001)). III. Analysis The Government argues that the Petition should be dismissed because Petitioner failed to exhaust all his administrative remedies with the BOP, and that doing so would not be futile.

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Related

Fuller v. Rich
11 F.3d 61 (Fifth Circuit, 1994)
Pack v. Yusuff
218 F.3d 448 (Fifth Circuit, 2000)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
United States v. Wilson
503 U.S. 329 (Supreme Court, 1992)
Correctional Services Corp. v. Malesko
534 U.S. 61 (Supreme Court, 2001)
Bobby Battle v. U.S. Parole Commission
834 F.2d 419 (Fifth Circuit, 1987)
United States v. Don Dowling
962 F.2d 390 (Fifth Circuit, 1992)
Ricardo Gallegos-Hernandez v. USA
688 F.3d 190 (Fifth Circuit, 2012)
United States v. Kevin Aparicio-Leon
963 F.3d 470 (Fifth Circuit, 2020)
United States v. Zaira Franco
973 F.3d 465 (Fifth Circuit, 2020)

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Mora v. Rosalez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mora-v-rosalez-txwd-2023.