Trinidad Balderas v. H.L. Ray

CourtDistrict Court, S.D. Georgia
DecidedMarch 3, 2026
Docket2:25-cv-00077
StatusUnknown

This text of Trinidad Balderas v. H.L. Ray (Trinidad Balderas v. H.L. Ray) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trinidad Balderas v. H.L. Ray, (S.D. Ga. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

TRINIDAD BALDERAS,

Petitioner, CIVIL ACTION NO.: 2:25-cv-77

v.

H.L. RAY,

Respondent.

ORDER AND REPORT AND RECOMMENDATION Petitioner Trinidad Balderas (“Balderas”), who was incarcerated at the Federal Correctional Institution in Jesup, Georgia, filed a 28 U.S.C. § 2241 Petition for Writ of Habeas Corpus. Doc. 1. Respondent filed a Motion to Dismiss Balderas’s Petition, and Balderas filed a Response. Docs. 7, 9. For the following reasons, I RECOMMEND the Court GRANT in part and DENY in part Respondent’s Motion to Dismiss and DISMISS without prejudice Balderas’s Petition, as supplemented, based on his failure to exhaust his administrative remedies. I also RECOMMEND the Court DIRECT the Clerk of Court to CLOSE this case and enter the appropriate judgment of dismissal and DENY Balderas in forma pauperis status on appeal. I GRANT Balderas’s Motion to Supplement, doc. 11. BACKGROUND Balderas was convicted in the District Court for the Eastern District of Tennessee of conspiracy to distribute 50 grams or more of methamphetamine, in violation of 21 U.S.C. §§ 846 and 841(a)(1) and (b)(1). Doc. 7-1 at 10. Balderas was sentenced to 135 months in prison. Balderas has a statutory release date of March 27, 2029, via good conduct release, and a projected release date of March 27, 2028, via First Step Act (“FSA”) release. Id. He has a home detention eligibility date of September 27, 2028. Id. It appears that Balderas is now at a residential reentry center. Doc. 15. In his Petition, Balderas asserts that the Bureau of Prisons (“BOP”) has incorrectly

calculated his credits under the FSA, in accordance with the clear language of 18 U.S.C. § 3624(g), and resulting in his over-detention. Doc. 1 at 18, 19. Balderas also states that he is entitled to credits under the Second Chance Act (“SCA”). Id. at 21. Balderas asks that the Court order the BOP to recalculate his risk assessment and the credit he is due. Id. at 20–21. Respondent asks this Court to dismiss Balderas’s Petition because Balderas failed to exhaust his administrative remedies regarding the claims he raises in this Petition. Doc. 7 at 3–5. Respondent states Balderas has no liberty interest in FSA credits. Id. at 5–7. Respondent also states that this Court lacks jurisdiction under the Administrative Procedures Act to review Balderas’s FSA claims and that this Court cannot determine Balderas’s place of confinement. Id. at 7–12. Respondent also states that other courts have determined that there is no statutory

mandate to transfer an eligible prisoner to pre-release custody as soon as he becomes eligible. Id. at 12. In addition, Respondent contends that Balderas’s risk assessment and credits have been properly calculated. Id. at 13–17. DISCUSSION I. Respondent Fails to Show That This Court Lacks Jurisdiction Under the APA to Review Balderas’s Claim

Balderas contends that the FSA provides that time credits “‘shall be applied toward time in prerelease custody or supervised release’ and the BOP ‘shall transfer eligible prisoners . . . into prerelease custody or supervised release.” Doc. 1 at 2 (citing 18 U.S.C. § 3632(d)(4)(C)). Balderas also contends that the FSA requires that these credits be applied toward pre-release custody or supervised release since the word “shall” is used in 18 U.S.C. § 3632(d)(4)(A). Id. In addition, “a prisoner is deemed ‘eligible’ for pre[-]release custody if he has earned sufficient earned time credits.” Id. at 8 (citing 18 U.S.C. § 3624(g)(1)). Balderas maintains that the BOP is required to transfer an eligible prisoner for placement at a halfway house or on home

confinement. Id. at 10. Respondent maintains that the Administrative Procedures Act (“APA”) bars this Court’s review of Balderas’s claims. Doc. 7 at 7. Respondent asserts that the BOP has the discretion to designate the place of a prisoner’s incarceration. Id. at 2, 11. Respondent also states that nothing in the FSA alters the BOP’s authority to make placement determinations. Id. at 10. Respondent characterizes Balderas’s claim as being a complaint about the location at which the BOP has chosen to place him, yet he fails to cite any authority allowing this Court to order his immediate RRC placement contrary to the BOP’s decision. Id. at 6–7. Balderas responds that this Court has jurisdiction under § 2241 because he is challenging the execution of his sentence. Doc. 9 at 5. He also states that the FSA mandates that his earned

credits be applied to pre-release custody or supervised release and the BOP’s refusal to apply his credits and provide him with RRC placement is not a discretionary decision; rather, Balderas asserts the BOP’s refusal to comply with the FSA is in violation of §§ 3624(g) and 3632(d)(4)(C). Id. at 4–6. Under the APA, a petitioner may use habeas corpus to challenge a BOP action. See 5 U.S.C. § 703. However, in 18 U.S.C. § 3625, Congress specified the provisions of the APA governing judicial review, §§ 701–06, were inapplicable to “the making of any determination, decision, or order under” any provision of 18 U.S.C. §§ 3621 to 3626. The Eleventh Circuit has explained § 3625 expressly precludes judicial review of agency adjudicative decisions but not rulemaking decisions, and courts generally lack jurisdiction because of § 3625 even in a § 2241 habeas action. Cook v. Wiley, 208 F.3d 1314, 1319 (11th Cir. 2000); see also Reeb v. Thomas, 636 F.3d 1224, 1227 (9th Cir. 2011) (“To find that prisoners can bring habeas petitions under 28 U.S.C. § 2241 to challenge the BOP’s discretionary determinations made pursuant to [Title 18,

Chapter 229, Subchapter C] would be inconsistent with the language of 18 U.S.C. § 3625.”); Martin v. Gerlinski, 133 F.3d 1076, 1079 (8th Cir. 1998) (“[I]t is apparent that § 3625 precludes judicial review of agency adjudicative decisions but not of rulemaking decisions.”). Where Congress precludes judicial review of an agency decision by statute, judicial review of that decision is limited to whether the agency acted outside its statutory limits or violated the Constitution. See Webster v. Doe, 486 U.S. 592, 597, 603 (1988); Santiago-Lebron v. Fla. Parole Comm’n, 767 F. Supp. 2d 1340, 1351 (S.D. Fla. 2011); Paradis v. Keller, 2011 WL 2790480, *4 n.3 (N.D. Ga. June 13, 2011); Klatch v. Rathman, No. 1:13-CV-01452, 2014 WL 537021, at *11 (N.D. Ala. Feb. 10, 2014); see also Rodriguez v. Johns, Civil Action No.

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Trinidad Balderas v. H.L. Ray, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trinidad-balderas-v-hl-ray-gasd-2026.