Paul v. Warden

CourtDistrict Court, S.D. West Virginia
DecidedMarch 14, 2025
Docket1:21-cv-00561
StatusUnknown

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

Bluebook
Paul v. Warden, (S.D.W. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA AT BLUEFIELD

MELVIN R. PAUL,

Plaintiff,

v. CIVIL ACTION NO. 1:21-00561

WARDEN, USP Coleman,

Defendant.

MEMORANDUM OPINION AND ORDER I. Introduction By Standing Order, this action was referred to United States Magistrate Judge Dwane L. Tinsley for submission of proposed findings and recommendation (“PF&R”). Magistrate Judge Tinsley submitted his proposed findings and recommendation on November 7, 2024. In that Proposed Findings and Recommendation, the magistrate judge recommended that this court deny plaintiff’s application for Writ of Habeas Corpus and remove this matter from the court’s docket. In accordance with the provisions of 28 U.S.C. § 636(b), the parties were allotted fourteen days, plus three mailing days, in which to file any objections to Magistrate Judge Tinsley’s Findings and Recommendation. The failure of any party to file such objections constitutes a waiver of such party's right to a de novo review by this court. Snyder v. Ridenour, 889 F.2d 1363 (4th Cir. 1989); Thomas v. Arn, 474 U.S. 140 (1985). Moreover, this court need not conduct a de novo review when a petitioner “makes general and conclusory objections that do not direct the court to a specific error in the magistrate’s proposed findings and recommendations.” Orpiano v. Johnson, 687 F.2d 44, 47 (4th

Cir. 1982). Plaintiff filed objections to the Proposed Findings and Recommendation on February 18, 2025. Because plaintiff filed his objections timely,1 this court has conducted a de novo review of the record as to those objections. See 28 U.S.C. § 636(b)(1) (“A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings and recommendations to which objection is made.”). II. Analysis On October 14, 2021, plaintiff filed an Application for Writ of Habeas Corpus by a Person in Federal Custody under 28 U.S.C. § 2241. In that filing, he asserted that the Bureau of Prisons (“BOP”) is improperly calculating his term of imprisonment.

Specifically, Paul wants to receive credit for time he spent in state custody prior to commencing his federal sentence. Magistrate Judge Tinsley concluded that 1) Paul’s federal

1 On December 4, 2024, the court granted plaintiff’s motion for an extension of the deadline to file objections. See ECF No. 21.

2 sentence did not commence until August 25, 2015, the day he was sentenced on federal charges; 2) Paul was discharged from his state sentences on March 1, 2015 and, therefore, he was not serving an undischarged state sentence at the time of his federal sentencing; and 3) the BOP properly granted Paul 176 days of

prior custody credit from March 2, 2015, the day he discharged his state sentences, through August 24, 2015, the day prior to the date his federal sentence commenced. Paul seeks a nunc pro tunc designation, which would allow his federal sentence to run concurrent with his state sentences that ended on March 1, 2015 or, in the alternative, he seeks prior custody credit for time spent in State custody from September 14, 2013, to the date his federal sentence commenced. “A federal sentence does not commence until the Attorney General receives the defendant into her ‘custody’ for service of that sentence.” United States v. Evans, 159 F.3d 908, 911 (4th Cir. 1998); 18 U.S.C. § 3585(a) (“A sentence to a term of

imprisonment commences on the date the defendant is received in custody. . . .”); see also United States v. Pungitore, 910 F.2d 1084, 1119 (3d Cir. 1990) (“a federal sentence does not begin to run until the defendant is delivered to the place where the sentence is to be served”). “When a federal court imposes a sentence on a defendant who is already in state custody, the

3 federal sentence may commence if and when the Attorney General or the Bureau of Prisons agrees to designate the state facility for service of the federal sentence.” Evans, 159 F.3d at 911-12. In deciding whether to make a nunc pro tunc designation, the BOP is guided by 18 U.S.C. § 3621(b), which provides as

follows: (b) Place of imprisonment. The Bureau of Prisons shall designate the place of the prisoner's imprisonment. . . . The Bureau may designate any available penal or correctional facility that meets minimum standards of health and habitability established by the Bureau, whether maintained by the Federal Government or otherwise and whether within or without the judicial district in which the person was convicted, that the Bureau determines to be appropriate and suitable, considering—

(1) the resources of the facility contemplated;

(2) the nature and circumstances of the offense;

(3) the history and characteristics of the prisoner;

(4) any statement by the court that imposed the sentence-

(A) concerning the purposes for which the sentence to imprisonment was determined to be warranted; or

(B) recommending a type of penal or correctional facility as appropriate; and

(5) any pertinent policy statement issued by the Sentencing Commission pursuant to section 994(a)(2) of title 28.

4 18 U.S.C. § 3621(b); Trowell v. Beeler, 135 F. App’x 590, 594 (4th Cir. 2005). As our appeals court has noted, “Section 3621(b) grants BOP wide latitude in selecting the place of a federal prisoner’s confinement. . . .” Id. at 593. Although the BOP must consider a prisoner's nunc pro tunc

designation request, it is not obligated to grant such a request. Barden v. Keohane, 921 F.2d 476, 478 (3d Cir. 1991); see also Trowell, 135 F. App’x at 595 (holding that the BOP “must exercise its own independent judgment, taking into account all applicable factors in § 3621(b), including the views of the sentencing court”). The BOP’s decision is reviewed for an abuse of discretion. See Trowell, 135 F. App’x at 593. Its decision in this regard is “entitled to a presumption of regularity and will not be disturbed in the absence of clear evidence to the contrary or abuse of discretion.” Loveless v. Ziegler, Civil Action No. 5:11-cv-00991, 2012 WL 3614315, *7 (S.D.W. Va. Aug. 21, 2012). As Magistrate Judge Tinsley noted, although the sentencing

court ordered Paul’s federal sentence to run concurrent with any undischarged term of imprisonment, that was “nothing more than an unfulfillable recommendation, as Petitioner had no undischarged state sentence remaining at the time of his federal sentencing.” ECF No. 19 at 10. Magistrate Judge Tinsley was correct as a district court does not have the authority to run a sentence

5 concurrent with a term of incarceration that has expired. See Morales v. Zenk, No. 10-4204, 414 F. App’x 383, 386 (3d Cir. Feb.

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Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Miguelo Morales v. Michael Zenk
414 F. App'x 383 (Third Circuit, 2011)
Kevin L. Barden v. Patrick Keohane, Warden
921 F.2d 476 (Third Circuit, 1991)
United States v. Robert Vaughn Evans
159 F.3d 908 (Fourth Circuit, 1998)
Rose v. Lee
252 F.3d 676 (Fourth Circuit, 2001)
Trowell v. Beeler
135 F. App'x 590 (Fourth Circuit, 2005)
United States v. Labeille-Soto
163 F.3d 93 (Second Circuit, 1998)
Snyder v. Ridenour
889 F.2d 1363 (Fourth Circuit, 1989)
United States v. Pungitore
910 F.2d 1084 (Third Circuit, 1990)

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Paul v. Warden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-v-warden-wvsd-2025.