Winfred Fields v. Warden Harrison

CourtDistrict Court, W.D. Tennessee
DecidedMarch 2, 2026
Docket2:25-cv-02676
StatusUnknown

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

Bluebook
Winfred Fields v. Warden Harrison, (W.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

WINFRED FIELDS, ) ) Petitioner, ) ) v. ) No. 2:25-cv-02676-SHL-atc ) WARDEN HARRISON, ) ) Respondent. )

ORDER DIRECTING CLERK TO MODIFY DOCKET, GRANTING RESPONDENT’S MOTION TO DISMISS, DISMISSING § 2241 PETITION WITHOUT PREJUDICE, CERTIFYING THAT AN APPEAL WOULD NOT BE TAKEN IN GOOD FAITH, AND DENYING LEAVE TO PROCEED IN FORMA PAUPERIS ON APPEAL

Before the Court is the pro se Petition for a Writ of Habeas Corpus Under 28 U.S.C. § 2241 (“§ 2241 Petition”) of Petitioner Winfred Fields.1 (ECF No. 2.) Respondent Warden Harrison has filed a Motion to Dismiss. (ECF No. 11.) Fields did not file a response to the Motion to Dismiss, and the time for doing so has expired. (See ECF No. 8.) For the reasons that follow, Harrison’s Motion to Dismiss (ECF No. 11) is GRANTED, and the § 2241 Petition is DISMISSED. I. BACKGROUND

1 At the time Fields filed his § 2241 Petition, he was an inmate at the Satellite Prison Camp in Millington, Tennessee (“SPC Millington”). (ECF No. 2 at PageID 2.) He is currently housed at the United States Penitentiary McCreary in Pine Knot, Kentucky. See bop.gov/inmateloc/ (click “Find By Number”; type 81687-479; then click “Search”) (last accessed Feb. 26, 2026). Fields is scheduled for release on December 30, 2027. Id. The Court DIRECTS the Clerk to modify the docket to note his current address. Following a twelve-day jury trial in the United States District Court for the Southern District of Texas, Fields was convicted of: (1) one count of conspiracy to commit mail fraud/wire fraud, in violation of 18 U.S.C. §§ 1341, 1343, and 1349; (2) one count of mail fraud, in violation of 18 U.S.C. § 1341; and (3) thirteen counts of aiding and assisting in the preparation

and presentation of false tax returns, in violation of 26 U.S.C. § 7206(2). See United States v. Fields, No. 4:18-cr-316 (S.D. Tex. July 9, 2019, ECF No. 44); see id. (S.D. Tex. Feb. 13, 2020, ECF No. 116). The court sentenced Fields to 108 months of incarceration, followed by a three- year term of supervised release. See id. (ECF No. 214). The United States Court of Appeals for the Fifth Circuit affirmed the convictions and sentences on January 12, 2022. See id. (ECF No. 259). On September 18, 2023, Fields filed a § 2255 Motion in the United States District Court for the Southern District of Texas, raising numerous claims of ineffective assistance of counsel and a claim that the indictment was constructively amended. See id. (ECF No. 268). Fields also filed a motion to reduce his sentence pursuant to 18 U.S.C. § 3582(c)(2) on November 1, 2023.

See id. (ECF No. 272). On March 5, 2024, the Government filed a Response to Fields’s § 2255 Motion. See id. (ECF No. 279). The sentencing-court denied the motion to reduce his sentence on December 26, 2024. See id. (ECF No. 283). The district court’s docket does not reflect that Fields’s § 2255 Motion has been ruled upon. II. THE PETITION Fields filed the instant § 2241 petition on June 30, 2025. (ECF No. 2.) He contends that he is “statutorily eligible for community-based pre-release custody under the First Step Act (FSA) and the Second Chance Act (SCA).” (Id. at PageID 2.) According to Fields, Harrison approved the referral for Fields to be placed in community-based custody on April 18, 2025. (Id.) Fields contends that, despite that approval, he “has not received a placement date and remains incarcerated.” (Id.) He asserts that he “has been eligible for community placement for over seven (7) months, and this continued delay directly contradicts [Bureau of Prisons] (BOP) policy mandating timely referrals and release.” (Id. at PageID 3.) Fields requests that the Court

“[w]aive the exhaustion requirement due to futility and irreparable harm” and order his immediate transfer “to community-based custody (home confinement or RRC).” (Id.) On July 10, 2025, Fields filed a supplement to his § 2241 Petition, asserting that, since the filing of his § 2241 Petition, the Residential Reentry Manager (the “RRM”) approved him for a placement date of August 27, 2026. (ECF No. 6 at PageID 12.) Fields contends that this placement date rejects his Unit Team’s recommendation, “which proposed a placement date of August 27, 2025, a date that incorporated 12 months of [SCA] prerelease placement.” (Id.) On July 28, 2025, Respondent filed a Motion to Dismiss the § 2241 Petition under Federal Rules of Civil Procedure 12(b)(1), 12(b)(6), and 56.1. (ECF No. 11 at PageID 24–26.) Respondent’s motion is supported by a Declaration of Robin Eads, a BOP paralegal with access

to official records for BOP inmates, including Fields’s Administrative Remedy History, which is also attached to the motion. (ECF No. 11-1.) Harrison argues that this Court should dismiss the § 2241 Petition based on Fields’s failure to exhaust his administrative remedies with the BOP. (ECF No. 11 at PageID 23, 26–29.) Harrison further argues that the § 2241 Petition should be denied on the merits because BOP decisions regarding placement in pre-release custody are not subject to judicial review and because the BOP has correctly applied Fields’s Earned Time Credits (“ETCs”) under the FSA to his sentence. (Id.) III. ANALYSIS This matter turns on the exhaustion issue. Although § 2241 does not contain an express statutory exhaustion requirement, federal inmates must generally exhaust all administrative remedies available before filing a § 2241 petition. See Little v. Hopkins, 638 F.2d 953, 953–54

(6th Cir. 1981) (“It is well established that federal prisoners complaining of events or conditions relating to their custody must exhaust their administrative remedies before habeas relief may be granted.”). The BOP has established a three-tiered Administrative Remedy Program by which an inmate may progressively redress grievances at the institutional, Regional, and Central Office (national) levels.2 See 28 C.F.R. § 542.10 et seq. “Complete exhaustion of administrative remedies is a prerequisite to seeking review of the BOP’s calculation of sentencing credit.” Cooper v. Batts, No. 21-5828, 2022 WL 4009862, at *2 (6th Cir. Aug. 25, 2022) (internal quotation marks and citation omitted). A prisoner’s failure to exhaust administrative remedies “may be excused where pursuing such remedies would be futile or unable to afford the petitioner the relief he seeks.” Fazzini v.

Ne. Ohio Corr. Ctr., 473 F.3d 229, 236 (6th Cir. 2006). Nonetheless, “[t]he Sixth Circuit requires some affirmative efforts to comply with the administrative procedures before analyzing whether the facility rendered these remedies unavailable.” Napier v. Laurel Cnty., 636 F.3d 218, 223 (6th Cir.

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