Brooks v. United States, 4:17-cv-00286

Kenneth Darrill Brooks, a federal prisoner, filed a document seeking a sentence modification under 18 U.S.C. § 3582(c) to obtain 15 months of credit for time served on a concurrent state sentence.
The district court treated the filing as a motion under § 3582(c) (after initially considering it under 28 U.S.C. § 2241) and screened it under 28 U.S.C. § 1915A.
Brooks did not allege that his sentence was based on a Sentencing Commission range that has been subsequently lowered (§ 3582(c)(2)).
He also did not allege that a statute or Federal Rule of Criminal Procedure 35 expressly permits the modification (§ 3582(c)(1)(B)).
The court applied the Twombly/Iqbal pleading standards and found Brooks’s allegations insufficient to state a claim for relief.
The court dismissed the petition sua sponte under § 1915A for failure to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brooks may obtain a sentence reduction under 18 U.S.C. § 3582(c) for 15 months of concurrent state jail credit	Brooks: § 3582(c) entitles him to modify his federal sentence to reflect earned jail-time credit from a concurrent state sentence	Government: Brooks pleaded no statutory basis for relief under § 3582(c)(1)(B) or (c)(2); no Rule 35 or statutory authorization alleged	Court: Dismissed—Brooks failed to allege a permissible basis under § 3582(c); pleading insufficient

Neitzke v. Williams, 490 U.S. 319 (1989) (defines frivolous pleadings standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must allege facts raising claim above speculative level)
Warth v. Seldin, 422 U.S. 490 (1975) (courts construe allegations favorably but need not accept unwarranted deductions)
Martin v. Scott, 156 F.3d 578 (5th Cir. 1998) (prisoner complaints subject to § 1915A screening)
Tuchman v. DSC Commc'ns Corp., 14 F.3d 1061 (5th Cir. 1994) (plaintiff must provide more than labels and conclusions)