ROYAL v. GABBY

CourtDistrict Court, N.D. Florida
DecidedAugust 19, 2024
Docket4:23-cv-00104
StatusUnknown

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

Bluebook
ROYAL v. GABBY, (N.D. Fla. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

VANESSA STAR ROYAL,

Petitioner, v. Case No. 4:23-cv-104/MW/MAL

WARDEN GABBY, F.C.I. TALLAHASSEE

Respondent. /

REPORT AND RECOMMENDATION Petitioner Vanessa Star Royal initiated this case in March of 2023 by filing a petition for writ of habeas corpus under 28 U.S.C. § 2241. In May of 2023, she filed an amended petition in which she claimed her offense of conviction is no longer a violent offense and she should not be disqualified from earning sentencing credits under the First Step Act (FSA). This case is before me on the Warden’s response in opposition to the amended § 2241 petition. ECF No. 11. Royal did not file a reply, despite having been afforded the opportunity to do so. After careful consideration of the petition, the Warden’s response, and relevant law, I recommend the § 2241 petition be denied because Royal did not exhaust her administrative remedies before filing her petition and her claim is otherwise without merit. Page 1 of 9 I. BACKGROUND In May of 2022, Petitioner Royal was sentenced in the Eastern District of North Carolina, Case 7:21cr68-BO, to a term of 84 months and one day’s imprisonment after pleading guilty to “bank robbery and aiding and abetting” in

violation of 18 U.S.C. §§ 2113(a), (d), and 2; and brandishing a firearm in furtherance of a crime of violence in violation of 18 U.S.C. §§ 924 (c)(1)(A)(ii), and 2. ECF No. 41. She is currently in custody at the Federal Correctional Institution in

Tallahassee, Florida with a projected release date of April 10, 2027. See https://www.bop.gov/inmateloc/. II. DISCUSSION In her amended petition, dated May 1, 2023, Royal raises a single ground for

relief. She claims the Bureau of Prisons (BOP) has misclassified her as being unable to receive FSA credits due to her offenses of conviction. ECF No. 8 at 3. In response to the question about exhaustion of administrative remedies, she states that she

received “no response from the Warden.” Id. at 3. In his response, the Warden contends the amended petition is subject to dismissal because Royal did not fully exhaust her administrative remedies. ECF No.

11. The Warden further notes that even if she had exhausted, Royal is statutorily

Page 2 of 9 barred from earning FSA credit due to her current convictions. Royal has presented nothing to rebut the Warden’s response. A. Exhaustion is required before filing a § 2241 petition. Prisoners are required to exhaust their administrative remedies before filing a

§ 2241 petition. Santiago-Lugo v. Warden, 785 F.3d 467, 471, 474-75 (11th Cir. 2015). Failure to exhaust is not a jurisdictional defect; rather, it is a defense that a respondent may assert, or choose to waive. Id. Respondent has not waived the

defense in this case. The BOP has the exclusive authority to compute sentence credit awards after sentencing. Rodriguez v. Lamer, 60 F.3d 745, 747 (11th Cir. 1995). As with other § 2241 claims, an inmate who wishes to challenge the BOP’s sentencing credit

calculations “must typically exhaust his or her administrative remedies with the BOP” before filing a § 2241 petition. Id; see also Jaimes v. United States, 168 F. App’x 356, 358-59 (11th Cir. 2006) (affirming dismissal of § 2241 petition for

failure to exhaust because inmate sought to challenge the computation of sentence credits without first going through the BOP’s administrative remedy procedure); see also Rey v. Warden, FCC Coleman-Low, 359 F. App’x 88, 91 (11th Cir. 2009)

(affirming denial of § 2241 challenging the BOP’s calculation of credit for time served because petitioner failed to exhaust administrative remedies).

Page 3 of 9 To properly exhaust administrative remedies, an inmate must comply with the prison’s deadlines and procedural rules. Blevins v. FCI Hazelton Warden, 819 F. App’x 853, 856 (11th Cir. 2020); Woodford v. Ngo, 548 U.S. 81, 90-91 (2006). To that end, the BOP has an administrative remedy procedure that allows an inmate to

raise issues related to any aspect of imprisonment. 28 C.F.R. § 542.10 et seq. The BOP’s administrative remedy procedure is a multi-tier system. See 28 C.F.R. §§ 542.10-542.19. Before seeking formal review, an inmate generally must first

attempt to resolve the matter informally by presenting her complaint to staff on a form commonly referred to as a BP-8. 28 C.F.R. § 542.13(a). If informal resolution is unsuccessful, the inmate may then initiate the formal review process. The full, formal BOP administrative remedy procedure has three steps. First,

the inmate must file a Request for Administrative Remedy, commonly referred to as a BP-9, with the warden of the facility. 28 C.F.R. § 542.14; see also Forde v. Miami Fed. Dep’t of Corr., 730 F. App’x 794, 798 (11th Cir. 2018) (citing Federal Bureau

of Prisons Inmate Admission & Orientation Handbook at 41; 28 C.F.R. § 542.14(a)- 542.15(a)). The deadline for completion of the BP-8 and submission of the BP-9 is twenty days from the date of the incident leading to the grievance, although an

extension may be granted if the inmate demonstrates a valid reason for delay. Id. If the inmate is dissatisfied with the warden’s response to the grievance, the inmate

Page 4 of 9 may appeal to the Regional Director by filing a Regional Administrative Remedy Appeal or BP-10. 28 C.F.R. § 542.15(a). This appeal must be filed within twenty days of the warden’s response to the grievance. Id. Finally, if the inmate is dissatisfied with the Regional Director’s response, the inmate may appeal to the

BOP’s Central Office by filing a Central Office Administrative Remedy Appeal, or BP-11. 28 C.F.R. § 542.15(a). This appeal must be filed within thirty days of the Regional Director’s response. Id. The appeal to the Central Office is the final

administrative level of appeal in the BOP. To fully exhaust, an inmate must properly complete each step of the BOP administrative remedy process. Woodford v. Ngo, 548 U.S. 81 (2006); Bryant v. Rich, 530 F.3d 1368, 1378 (11th Cir. 2008) (citation omitted); Blevins, 819 F. App’x at 856. If the inmate does not receive a response

within the time allotted for reply at any level, including extension, the inmate may consider the absence of a response to be a denial at that level. 28 C.F.R. § 542.18.

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Related

Franco Tinoco Jaimes v. United States
168 F. App'x 356 (Eleventh Circuit, 2006)
Nelson Rey v. Warden, FCC Coleman - Low
359 F. App'x 88 (Eleventh Circuit, 2009)
Bryant v. Rich
530 F.3d 1368 (Eleventh Circuit, 2008)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Angel Cintron Rodriguez v. J.D. Lamer
60 F.3d 745 (Eleventh Circuit, 1995)
Israel Santiago-Lugo v. Warden
785 F.3d 467 (Eleventh Circuit, 2015)
United States v. Taylor
596 U.S. 845 (Supreme Court, 2022)

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