Susan Andrea Cavadas v. Ricolcol

CourtDistrict Court, C.D. California
DecidedJanuary 21, 2025
Docket2:24-cv-09193
StatusUnknown

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

Bluebook
Susan Andrea Cavadas v. Ricolcol, (C.D. Cal. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES—GENERAL

Case No. 2:24-cv-09193-JGB-KES Date: January 21, 2025

Title: SUSAN ANDREA CAVADAS v. WARDEN RICOLCOL

PRESENT:

THE HONORABLE KAREN E. SCOTT, U.S. MAGISTRATE JUDGE

Jazmin Dorado Not Present Courtroom Clerk Court Reporter

ATTORNEYS PRESENT FOR ATTORNEYS PRESENT FOR PETITIONER: RESPONDENT: None Present None Present

PROCEEDINGS (IN CHAMBERS): Order Requiring Petitioner to Respond to the Motion to Dismiss (Dkt. 14)

I. BACKGROUND A. Initial Petition On October 16, 2024, Susan Andrea Cavadas (“Petitioner”) constructively1 filed a petition for writ of habeas corpus under 28 U.S.C. § 2241. (“Petition” at Dkt. 1.) Petitioner is an inmate in the custody of the Federal Bureau of Prisons (“BOP”) housed at FCI Victorville. (Id. at 1.) According to BOP public records, her current release date is November 22, 2025. See BOP Inmate Locator, https://www.bop.gov/inmateloc/. The Petition alleged that on January 18, 2024, Petitioner was sentenced to 62 months in

1 “Under the mailbox rule, a prisoner’s pro se habeas petition is deemed filed when he hands it over to prison authorities for mailing to the relevant court.” Campbell v. Henry, 614 F.3d 1056, 1058-59 (9th Cir. 2010) (citation omitted); see also Houston v. Lack, 487 U.S. 266, 268 (1988). A court generally deems a habeas petition filed on the day it is signed, because it assumes the petitioner turned the petition over to prison authorities for mailing that day. See Butler v. Long, 752 F.3d 1177, 1178 n.1 (9th Cir. 2014); Roberts v. Marshall, 627 F.3d 768, 770 n.1 (9th Cir. 2010). CIVIL MINUTES – GENERAL

Case No. 2:24-cv-09193-JGB-KES Date: January 21, 2025 Page 2

custody to be followed by 3 years of supervised release. (Pet. at 1.)2 It further contended that she should have been released on August 8, 2024, if the BOP had properly awarded her jail credit, First Step Act (“FSA”) earned time credits (“ETCs”), good time credits (“GTCs”), and Second Chance Act (“SCA”) credits. (Id.) The Petition attached a BOP form entitled, “FSA Time Credit Assessment” and dated October 10, 2024. (Id. at 5-6.) The form lists Petitioner’s projected release date as November 22, 2025, but it also lists an “FSA Projected Release Date” of November 12, 2025 and an “SCA Conditional Placement Date” of August 4, 2024. (Id.) The form also states, “SCA days are not guaranteed and require an individualized assessment! … This date is subject to change based on the required five-factor review under 18 USC sec. 3621(b).” (Id.) The Petition appeared to admit that Petitioner had not exhausted her administrative remedies. It asserted that “administrative remedies [are] not available and therefore [are] futile. … Ross [v. Blake, 578 U.S. 32 (2016)] outlined 3 ways that grievance procedures might be ‘unavailable’ to incarcerated people in practice[;] one is preventing prisoners from pursuing their administrative remedies which is the case here.” (Id. at 2.) B. First Amended Petition The Court dismissed the Petition with leave to amend, finding that Petitioner would need to add more facts explaining how and why she believed the BOP’s administrative remedies were unavailable. (Dkt. 5.) Petitioner constructively filed a First Amended Petition (“FAP” at Dkt. 7) on November 23, 2024. The FAP alleges that on October 23, 2024—about a week after Petitioner signed the initial Petition and the same day it was received by the Court—Petitioner “asked Counselor Diaz for a BP-8 to begin [her] administrative remedies … but was denied a BP-8. … Counselor Diaz is the gate keeper to the administrative remedies forms, and can only get it from her…. Counselor Unit Team Lujan said I had to get it from her.” (Id. at 1-2.) The Court ordered Respondent to respond to the FAP. (Dkt. 9.) Respondent has now filed a motion to dismiss the FAP based on Petitioner’s failure to exhaust her administrative remedies with the BOP. (Dkt. 14.) II. LEGAL STANDARD To seek habeas relief under § 2241, “a petitioner must first, as a prudential matter, exhaust his or her available administrative remedies.” Singh v. Napolitano, 649 F.3d 899, 900

2 This appears to be consistent with available public records. See United States v. Cavadas, No. 4:21-cr-00184-ALM-AGD(2) (E.D. Tex. Jan. 19, 2024) (criminal judgment showing Petitioner pled guilty to conspiracy to possess with intent to manufacture and distribute 500 grams or more of methamphetamine and sentenced to 62 months). CIVIL MINUTES – GENERAL

Case No. 2:24-cv-09193-JGB-KES Date: January 21, 2025 Page 3

(9th Cir. 2011). This exhaustion requirement serves several purposes. It “aid[s] judicial review by allowing the appropriate development of a factual record in an expert forum”; it “conserve[s] the court’s time because of the possibility that the relief applied for may be granted at the administrative level”; and it “allow[s] the administrative agency an opportunity to correct errors occurring in the course of administrative proceedings.” Ruviwat v. Smith, 701 F.2d 844, 845 (9th Cir. 1983); see also Montes v. Thornburgh, 919 F.2d 531, 537 (9th Cir. 1990) (noting that courts may require exhaustion as a prudential matter where, e.g., “agency expertise makes agency consideration necessary to generate a proper record and reach a proper decision” and “relaxation of the requirement would encourage the deliberate bypass of the administrative scheme”). However, the “exhaustion requirement is subject to waiver in § 2241 cases because it is not a ‘jurisdictional prerequisite.’” Ward v. Chavez, 678 F.3d 1042, 1045 (9th Cir. 2012) (citation omitted). “[E]xhaustion can be waived if pursuing those [administrative] remedies would be futile.” Id. at 1045; see also Green v. Carlson, 884 F.2d 1394, *2 (9th Cir. 1989) (table) (citing United Farm Workers v. Arizona Agricultural Employment Relations Bd., 669 F.2d 1249, 1253 (9th Cir. 1982)). Exhaustion may be futile “where the agency’s position on the question at issue appears already set, and it is very likely what the result of recourse to administrative remedies would be….” El Rescate Legal Servs., Inc. v. Executive Off. of Immigr. Review, 959 F.2d 742, 747 (9th Cir. 1991) (internal quotation marks omitted); see also Ward, 678 F.3d at 1045-46 (finding exhaustion would be futile because BOP’s denial of relief was based on official BOP policy). The BOP has a four-tiered administrative remedy process for inmates challenging issues related to their imprisonment. 28 C.F.R. §§ 542.10-542.19. First, the inmate can seek informal resolution of the issue of concern at the inmate’s institution of confinement using a BP-8 form. 28 C.F.R.

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Related

Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Campbell v. Henry
614 F.3d 1056 (Ninth Circuit, 2010)
Roberts v. Marshall
627 F.3d 768 (Ninth Circuit, 2010)
Ward v. Chavez
678 F.3d 1042 (Ninth Circuit, 2012)
Anthony Butler v. David Long
752 F.3d 1177 (Ninth Circuit, 2014)
Singh v. Napolitano
649 F.3d 899 (Ninth Circuit, 2010)

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Bluebook (online)
Susan Andrea Cavadas v. Ricolcol, Counsel Stack Legal Research, https://law.counselstack.com/opinion/susan-andrea-cavadas-v-ricolcol-cacd-2025.