Noe v. Ciolli

CourtCourt of Appeals for the Tenth Circuit
DecidedApril 15, 2024
Docket23-1304
StatusUnpublished

This text of Noe v. Ciolli (Noe v. Ciolli) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Noe v. Ciolli, (10th Cir. 2024).

Opinion

Appellate Case: 23-1304 Document: 010111031853 Date Filed: 04/15/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT April 15, 2024 _________________________________ Christopher M. Wolpert Clerk of Court PETER GEORGE NOE,

Petitioner - Appellant,

v. No. 23-1304 (D.C. No. 1:22-CV-01618-LTB-STV) A. CIOLLI, (Warden), (D. Colo.)

Respondent - Appellee. _________________________________

ORDER AND JUDGMENT * _________________________________

Before MATHESON, BALDOCK, and McHUGH, Circuit Judges. _________________________________

Peter George Noe is a federal prisoner housed at the USP Florence ADX

(ADX) detention facility operated by the Bureau of Prisons (BOP). Proceeding

pro se, he filed an application in the United States District Court for the District of

Colorado for a writ of habeas corpus under 28 U.S.C. § 2241, which he later

amended. He appeals from the district court’s order dismissing his amended

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 23-1304 Document: 010111031853 Date Filed: 04/15/2024 Page: 2

application for lack of statutory jurisdiction. Exercising jurisdiction under 28 U.S.C.

§ 1291, we affirm.

I

Noe asserted two claims in his amended application under § 2241. First, he

challenged the BOP’s implementation of the First Step Act (Act) at ADX. Second,

he recognized that the BOP’s system for implementing good-time credits under the

Act properly uses a prisoner’s criminal history score from their presentence report;

however, he maintained that he was wrongly denied good-time credits because his

presentence report contains errors that resulted in a criminal history score that was

too high. For relief, Noe requested that he “be resentenced to correct the sentencing

errors in his [presentence report] to allow him to earn his full [good-time] credits.”

R., vol. I at 42.

Because § 2241 applications must be brought in the district where the prisoner

is incarcerated, Noe filed his application in federal district court in Colorado. Later,

he filed a motion to transfer claim two to the United States District Court for the

District of Minnesota—the court in which he was convicted and sentenced. Noe

maintained that transfer was “in the interest of justice” because claim two “deals with

errors” in the presentence report and the “sentencing judge knows of the errors, the

case, and has all of the documents and records in the case.” R., vol. I at 96.

A magistrate judge recommended that the first claim be dismissed as

duplicative because the same claim was pending in a different suit by Noe against

USP-ADX. Further, the magistrate judge recommended that the second claim be

2 Appellate Case: 23-1304 Document: 010111031853 Date Filed: 04/15/2024 Page: 3

dismissed without prejudice for lack of statutory jurisdiction and denied the

motion to transfer.

Noe filed objections to the report and recommendation. While the

objections were pending, he filed a motion to voluntarily dismiss the first claim.

The district court (1) overruled Noe’s objections; (2) dismissed the first claim under

Fed. R. Civ. P. 41(a)(1)(A)(i); (3) adopted the magistrate judge’s recommendation

and dismissed the second claim without prejudice for lack of subject-matter

jurisdiction; and (4) denied Noe’s motion to proceed without prepayment of fees on

appeal.

II

“We review the district court’s dismissal of a § 2241 habeas petition de novo.”

Brace v. United States, 634 F.3d 1167, 1169 (10th Cir. 2011) (internal quotation

marks omitted). Because Noe proceeds pro se, we construe his pleadings liberally.

See id.

III

A federal prisoner may pursue habeas relief under two statutes. The first is

§ 2241. An application under § 2241 “typically attacks the execution of a sentence

rather than its validity and must be filed in the district where the prisoner is

confined.” Brace, 634 F.3d at 1169 (internal quotation marks omitted). The second

avenue of relief is 28 U.S.C. § 2255. “Congress created § 2255 as a separate

remedial vehicle specifically designed for federal prisoners’ collateral attacks on

their sentences.” Jones v. Hendrix, 599 U.S. 465, 473 (2023). “A § 2255 motion is

3 Appellate Case: 23-1304 Document: 010111031853 Date Filed: 04/15/2024 Page: 4

ordinarily the only means to challenge the validity of a federal conviction following

the conclusion of direct appeal.” Hale v. Fox, 829 F.3d 1162, 1165 (10th Cir. 2016).

“But in rare instances,” the “savings clause in § 2255(e)” permits a prisoner to

attack a conviction through a § 2241 habeas corpus application. Hale, 829 F.3d at

1165 (citation and internal quotation marks omitted). The saving clause provides:

An application for a writ of habeas corpus [pursuant to § 2241] in behalf of a prisoner who is authorized to apply for relief by motion pursuant to [§ 2255], shall not be entertained if it appears that the applicant has failed to apply for relief, by motion, to the court which sentenced him, or that such court has denied him relief, unless it also appears that the remedy by motion [pursuant to § 2255] is inadequate or ineffective to test the legality of his detention. 28 U.S.C. § 2255(e) (emphasis added). The applicant “bears the burden of showing

he satisfies § 2255(e).” Hale, 829 F.3d at 1170.

In Jones, the Court explained that the circumstances in which the saving clause

applies are narrow and “cover[] unusual circumstances in which it is impossible or

impracticable for a prisoner to seek relief from the sentencing court” in a § 2255

motion. 599 U.S. at 474 (giving examples such as the dissolution of the sentencing

court).

Putting a slightly finer point on the issue, the test for whether a supposed

§ 2241 falls within the saving clause is “whether a petitioner’s argument challenging

the legality of his detention could have been tested in an initial § 2255 motion.”

Prost v. Anderson, 636 F.3d 578, 584 (10th Cir. 2011) (Gorsuch, J.). “If the answer

is yes, then the petitioner may not resort to the savings clause and § 2241.” Id. This

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Prost v. Anderson
636 F.3d 578 (Tenth Circuit, 2011)
Brace v. United States
634 F.3d 1167 (Tenth Circuit, 2011)
Hale v. Fox
829 F.3d 1162 (Tenth Circuit, 2016)
Jones v. Hendrix
599 U.S. 465 (Supreme Court, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Noe v. Ciolli, Counsel Stack Legal Research, https://law.counselstack.com/opinion/noe-v-ciolli-ca10-2024.