Smith v. Wilson

CourtDistrict Court, E.D. Virginia
DecidedJanuary 3, 2023
Docket3:21-cv-00722
StatusUnknown

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

Bluebook
Smith v. Wilson, (E.D. Va. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division ANTONIO MARCELLUS SMITH, Petitioner, Vv. Civil No. 3:21¢v722 (DJN) DAVID LEU, Respondent.! MEMORANDUM OPINION Antonio Marcellus Smith, a federal inmate proceeding pro se, submitted this 28 U.S.C. § 2241 Petition. (“§ 2241 Petition,” ECF No. 1.)? Smith raises the following grounds for relief? Claim One: Smith was “denied access to a program granted by Congress, the First Step Act [(“FSA”)], and because of this, [he did] not receiv[e] the benefits of said program.” (§ 2241] Petition at 6.)

] According to Respondent, Robert Wilson is no longer the acting warden at the Federal Correctional Complex in Petersburg, Virginia (“FCC Petersburg”). (Government’s Reply (ECF No. 11) at 1 n.1.) The current warden at FCC Petersburg is David Leu. (/d.) The Clerk is DIRECTED to update the docket and the case caption accordingly. 2 The statute provides, in pertinent part, that: (c) The writ of habeas corpus shall not extend to a prisoner unless-- (1) He is in custody under or by color of the authority of the United States or is committed for trial before some court thereof; or (2) He is in custody for an act done or omitted in pursuance of an Act of Congress, or an order, process, judgment or decree of a court or judge of the United States; or (3) He is in custody in violation of the Constitution or laws or treaties of the United States.... 28 U.S.C.A. § 2241(c)(1)}H3). 3 The Court employs the pagination assigned by the CM/ECF docketing system for citations to the record. The Court corrects the capitalization, punctuation, and spelling in quotations from the parties’ submissions.

Claim Two: FCC Petersburg “never instituted an alternative plan to deal with the [COVID-19] pandemic and provide [FSA programing].” (§ 2241 Petition at 7.) Claim Three: “Other facilities were able to continue administering [FSA programing] during the pandemic.” (§ 2241 Petition at 7.) Claim Four: FCC Petersburg “had alternative avenues available to them [to implement FSA programing] but chose not to use them.” (§ 2241 Petition at 8.) Aside from being wholly conclusory, see Sanders v. United States, 373 US. 1, 19 (1963) (finding denial of habeas petition appropriate where it “stated only bald legal conclusions with no supporting factual allegations”), Claims One through Four are redundant, stating, at their core, only one ground for relief. Specifically, Smith asserts that the staff at FCC Petersburg violated his rights by not offering him as many FSA programs as he thought were appropriate during the COVID-19 pandemic. Accordingly, the Court will address Claims One through Four collectively. The Government has filed a Motion to Dismiss in which it argues that this Court lacks jurisdiction to hear Smith’s claims, that Smith failed to exhaust his administrative remedies and that Smith’s claims otherwise lack merit. (Motion to Dismiss and Supporting Memorandum (ECF Nos. 7, 8).) On June 27, 2022, while he was still incarcerated at FCC Petersburg, Smith filed a response. (See Response (ECF No. 9) at 13 (listing Petersburg Medium as Smith’s address).) A little over one week later, on July 5, 2022, Smith was released from custody. (See Government’s Reply at 2-3 (“[T]he BOP released Petitioner on July 5, 2022, to his term of supervised release.); see also ECF No. 10, at 1 (Petitioner’s Notice of Change of Address).)* This change in circumstance prompted Respondent to argue that Smith’s claims have been rendered moot. (Government’s Reply at 2-3.) Specifically, Respondent contends that:

4 The Bureau of Prisons (“BOP”) Inmate Locator confirms Smith’s release on July 5, 2022. See https://www.bop.gov/inmateloc// (select “Find By Number,” type 85569-083 in the field provided, and follow the “search” button) (last vjsited January 3, 2023).

Petitioner was previously projected to be released from his federal sentence on February 10, 2023. However, . . . staff at [FCC Petersburg] routinely conducted an updated risk assessment to determine Petitioner’s eligibility to receive time credit for his participation in eligible programing under the [FSA]. During this assessment, Petitioner’s risk recidivism level was reduced from a “medium-risk” to a “low-risk.” Thus, Petitioner became eligible for the application of FSA time credits. As Petitioner had earned FSA time credits during his incarceration, the credits were applied towards early transfer to supervised release once BOP staff assessed Petitioner at a “low-risk” recidivism level. Subsequently, and due to his FSA earned time credits, the BOP released Petitioner on July 5, 2022, to his term of supervised release. Therefore, Petitioner’s earned time credits under the FSA have been applied towards his supervised release, and he has, in fact been released from federal custody; thus, Petitioner has already received any relief he could be provided in connection with the relief requested in this Petition... (Government’s Reply at 2—3 (internal citations omitted).) Smith has not responded to the Government’s argument that his claims are moot, nor has he communicated with the Court since his release from incarceration. Accordingly, and as discussed below, the Motion to Dismiss (ECF No. 7) will be GRANTED, and both the § 2241 Petition (ECF No. 1) and this action will be DISMISSED as MOOT. I. STANDARD OF REVIEW In a motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) challenging the Court’s subject matter jurisdiction, the burden rests with the petitioner, as the party asserting jurisdiction, to prove that federal jurisdiction is proper. See Int’l Longshoremen’s Ass'n v. Va. Terminals, Inc., 914 F. Supp. 1335, 1338 (E.D. Va. 1996) (citing McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178, 189 (1936); Adams v. Bain, 697 F.2d 1213, 1219 (4th Cir. 1982)). A motion to dismiss pursuant to Rule 12(b)(1) can attack subject matter jurisdiction in two ways. First, a Rule 12(b)({1) motion may attack the petition on its face, asserting that the petition fails to state a claim upon which subject matter jurisdiction can lie. See id. (citing Adams, 697 F.2d at 1219).

Alternatively, a Rule 12(b)(1) motion may challenge the existence of subject matter jurisdiction in fact, apart from the pleadings. Richmond, Fredericksburg & Potomac R.R. v. United States, 945 F.2d 765, 768 (4th Cir. 1991); Int’! Longshoremen’s Ass’n, 914 F. Supp. at 1338; see also Adams, 697 F.2d at 1219 (explaining that “it may be contended that a complaint simply fails to allege facts upon which subject matter jurisdiction can be based”). In such a case, “the district court may then go beyond the allegations of the [petition] and resolve the jurisdictional facts in dispute by considering evidence outside the pleadings, such as affidavits.” United States ex rel. Vuyyuru v. Jadhav, 555 F.3d 337, 348 (4th Cir. 2009) (citations omitted). Consideration of evidence outside of the pleadings on a Rule 12(b)(1) motion does not necessarily convert the motion to one for summary judgment. Evans v. B.F. Perkins Co., 166 F.3d 642, 647 (4th Cir. 1999) (citation omitted); McBurney v. Cuccinelli, 616 F.3d 393, 409 (4th Cir. 2010) (Agee, J., concurring in part and dissenting in part) (discussing that motions under Rule 12(b)(1) are not restricted by Rule 12(d)).

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Related

McNutt v. General Motors Acceptance Corp.
298 U.S. 178 (Supreme Court, 1936)
Powell v. McCormack
395 U.S. 486 (Supreme Court, 1969)
Allen v. Wright
468 U.S. 737 (Supreme Court, 1984)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
McBurney v. Cuccinelli
616 F.3d 393 (Fourth Circuit, 2010)
David Wayne Evans v. B.F. Perkins Company
166 F.3d 642 (Fourth Circuit, 1999)
South Carolina Citizens for Life, Inc. v. Krawcheck
301 F. App'x 218 (Fourth Circuit, 2008)
United States Ex Rel. Vuyyuru v. Jadhav
555 F.3d 337 (Fourth Circuit, 2009)
United States v. Shelton Ketter
908 F.3d 61 (Fourth Circuit, 2018)
Adams v. Bain
697 F.2d 1213 (Fourth Circuit, 1982)
Ross v. Reed
719 F.2d 689 (Fourth Circuit, 1983)

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Bluebook (online)
Smith v. Wilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-wilson-vaed-2023.