Rios v. Quiros

CourtDistrict Court, D. Connecticut
DecidedAugust 11, 2025
Docket3:24-cv-01152
StatusUnknown

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

Bluebook
Rios v. Quiros, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

-------------------------------- x ALBERTO RIOS, : : Petitioner, : : v. : : Civil No. 3:24-cv-1152 (AWT) ANGEL QUIROS, COMMISSIONER OF : CORRECTION, : : Respondent. : -------------------------------- X

RULING ON MOTION TO DISMISS Petitioner Alberto Rios filed a petition for a writ of habeas corpus pro se against respondent Commissioner of Correction Angel Quiros, challenging the execution of his sentence pursuant to a State court judgment. He claims his sentence is being executed in violation of the Ex Post Facto Clause of the United States Constitution. See U.S. Const., Art. I, § 10, cl. 1. Rios purports to bring this action pursuant to 28 U.S.C § 2241, but because he is a State prisoner claiming that he is in custody in violation of the Constitution of the United States, the court treats his habeas petition as one brought pursuant to 28 U.S.C. § 2254. See Cook v. N.Y. State Div. of Parole, 321 F.3d 274, 277 (2d Cir. 2003) (“[I]f an application that should be brought under 28 U.S.C. § 2254 is mislabeled as a petition under section 2241, the district court must treat it as a section 2254 application instead.”). The respondent has moved to dismiss the petition under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim on which relief can be granted. For the reasons that follow, the respondent’s motion to dismiss is being granted. I. BACKGROUND The petitioner “was convicted, in connection with conduct occurring on April 22, 2013, of assault in the first degree in

violation of [Connecticut] General Statutes § 53a-59 (a) (1), assault in the second degree in violation of [Connecticut] General Statutes § 53a-60, and three counts of reckless endangerment in the first degree in violation of [Connecticut] General Statutes § 53a-63.” Rios v. Comm’r of Corr., 224 Conn. App. 350, 354 (2024). “On May 15, 2014, he was sentenced to twenty years of incarceration, suspended after fourteen years, followed by five years of probation.” Id. Connecticut General Statutes § 18-98e, which governs the risk reduction earned credits (“RREC”) program, provides, in relevant part:

(a) Notwithstanding any provision of the general statutes, any person sentenced to a term of imprisonment for a crime committed on or after October 1, 1994, and committed to the custody of the Commissioner of Correction on or after said date, [with certain exceptions], may be eligible to earn risk reduction credit toward a reduction of such person’s sentence, in an amount not to exceed five days per month, at the discretion of the Commissioner of Correction for conduct as provided in subsection (b) of this section occurring on or after April 1, 2006. (b) An inmate may earn risk reduction credit for adherence to the inmate’s offender accountability plan, for participation in eligible programs and activities, and for good conduct and obedience to institutional rules as designated by the commissioner, provided (1) good conduct and obedience to institutional rules alone shall not entitle an inmate to such credit, and (2) the commissioner or the commissioner’s designee may, in his or her discretion, cause the loss of all or any portion of such earned risk reduction credit for any act of misconduct or insubordination or refusal to conform to recommended programs or activities or institutional rules occurring at any time during the service of the sentence or for other good cause. If an inmate has not earned sufficient risk reduction credit at the time the commissioner or the commissioner’s designee orders the loss of all or a portion of earned credit, such loss shall be deducted from any credit earned by such inmate in the future. . . .

(f) The commissioner shall adopt policies and procedures to determine the amount of credit an inmate may earn toward a reduction in his or her sentence and to phase in the awarding of retroactive credit authorized by subsection (c) of this section.

Conn. Gen. Stat. § 18-98e. At issue here is one of those policies and procedures adopted by the Commissioner, Administrative Directive 4.2A. With respect to Administrative Directive 4.2A, the Connecticut Appellate Court explained: The administrative directive of the Department of Correction (department) concerning the earning of RREC that was in effect at the time the petitioner committed the underlying offenses was administrative directive 4.2A (2013 administrative directive). Conn. Dept. of Correction, Administrative Directive 4.2A (effective March 22, 2013). That administrative directive provided that risk reduction credit is “[t]ime awarded at the discretion of the [respondent] or designee at the rate of five (5) days per month for participation in programs or activities, good conduct and obedience to departmental rules, unit and/or program rules in accordance with RREC guidelines as determined by the [respondent] or designee.” Administrative Directive 4.2A (3) (D) (effective March 22, 2013).

Pursuant to the 2013 administrative directive, once an incarcerated individual signs an offender accountability plan and adheres to the rules and regulations, RREC is calculated and awarded via the department's computer system at a rate of five days per month. The petitioner earned RREC at the rate of five days per month under the 2013 administrative directive.

Rios, 224 Conn. App. at 354-55. “On February 1, 2016, the 2013 administrative directive was amended.” Id. at 355. “That amendment, which is reflected in administrative directive 4.2A (2016 administrative directive), provides that ‘[a]n inmate may earn RREC at the rate of three (3) days per month as an Overall Level 4 inmate, four (4) days per month as an Overall Level 2 or 3 inmate and five (5) days per month as an Overall Level 1 inmate or if the inmate is being supervised in the community on early release supervision throughout the sentenced portion of the inmate's incarceration.’” Id. (quoting Conn. Dept. of Correction, Administrative Directive 4.2A (6) (effective February 1, 2016)). “The petitioner had been earning five days of RREC under the 2013 administrative directive.” Id. at 355. “Under the 2016 administrative directive, the petitioner began earning RREC at a rate of three days per month due to his risk classification as an overall level 4 inmate.” Id. “On February 1, 2018, the petitioner’s classification changed to an overall level 3 inmate, thereby allowing him to earn RREC at a rate of four days per month.” Id. “The petitioner earned approximately forty-six fewer days of RREC than he would have received from March 1, 2016, to February 1, 2018, if the 2013 administrative directive had been applied to him during that time period.” Id. “From

February 1, 2018, until the time of the habeas proceedings, the petitioner earned approximately fifty-eight fewer days of RREC pursuant to the 2016 administrative directive.” Id. at 355-56.

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