Credico v. Warden, FCI Allenwood Medium, 3:18-cv-00465

Petitioner Justin Credico, a former federal inmate at FCI-Allenwood, filed a 28 U.S.C. § 2241 habeas petition challenging his SHU placement pending an SIS investigation and seeking placement in a Residential Re-Entry Center (RRC) under the Second Chance Act.
Credico argued he should not be denied RRC placement for refusing to work because his criminal judgment did not order him to perform BOP work.
The Court dismissed the habeas petition on February 1, 2019 for failure to exhaust administrative remedies and as not ripe.
Credico moved for reconsideration, reiterating challenges to RRC denial and loss of good conduct time.
The Court found Credico was released from BOP custody on April 5, 2019, rendering his challenges moot and concluded the reconsideration motion did not meet Rule 59(e) grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of RRC placement for refusal to work violated Credico's rights under the Second Chance Act	Credico: RRC should not be denied because his judgment did not require BOP work	BOP: Placement decisions tied to BOP policies and administrative process; exhaustion required	Court did not reach the merits; claim dismissed earlier for non-exhaustion and ripeness and now moot due to release
Whether loss of good conduct time claim was reviewable	Credico: loss of GCT was wrongful and reviewable	Respondent: administrative remedies and BOP procedures govern; issues not ripe/exhausted	Court found claim moot after Credico's release and previously dismissed for failure to exhaust
Whether Credico exhausted administrative remedies before filing § 2241	Credico: challenged denial despite lacking exhaustion	Respondent: asserted failure to exhaust and lack of ripeness	Court held Credico failed to exhaust and petition was not ripe; dismissal appropriate
Whether reconsideration under Fed. R. Civ. P. 59(e) is warranted	Credico: requested reconsideration of February 1, 2019 Order	Respondent: opposed; no intervening law or new evidence	Court denied motion: no intervening change in law, no new evidence, no clear error or manifest injustice; motion was relitigation

United States v. Fiorelli, 337 F.3d 282 (3d Cir. 2003) (Rule 59(e) used to correct analytical errors)
Max's Seafood Café ex rel. Lou-Ann, Inc. v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for granting reconsideration under Rule 59(e))
Waye v. First Citizen's Nat. Bank, 846 F. Supp. 310 (M.D. Pa. 1994) (reconsideration not for reargument or presenting previously neglected arguments)
Rohrbach v. AT&T Nassau Metals Corp., 902 F. Supp. 523 (M.D. Pa. 1995) (grounds for reconsideration include misunderstanding or error of apprehension)
Above the Belt, Inc. v. Mel Bohannan Roofing, Inc., 99 F.R.D. 99 (E.D. Va. 1983) (describing narrow circumstances warranting reconsideration)
D'Angio v. Borough of Nescopeck, 56 F. Supp. 2d 502 (M.D. Pa. 1999) (reconsideration is extraordinary and granted sparingly)