Dyson v. Fox, Civil Action No. 2017-1265

Petitioner Darnell Leon Dyson Jr., incarcerated at USP Florence ADMAX in Colorado, filed a 28 U.S.C. § 2241 habeas petition in the D.C. District Court challenging events at his facility.
Dyson alleges he was forced to provide a urine sample (and to drink fluids while fasting for Ramadan), threatened with bodily harm/waterboarding, lost 40 days of good-time credit, was placed in disciplinary segregation, lost visiting privileges, and was transferred to ADMAX ill-suited for his disabilities.
BOP records attached to the petition state Dyson refused to provide a urine sample, declined to drink water, and confirm the sanctions (40 days good-time loss, 30 days segregation, 6-month visiting ban).
Dyson seeks release from custody, restoration of 40 days of good-time credit, a medical transfer, a declaratory judgment of religious-rights violations, and $100,000 in punitive damages.
The court held that requests for damages and a past declaratory judgment are not cognizable in habeas and require a separate civil action (with the $400 filing fee or IFP status). Habeas relief challenging custody must be brought in the district of confinement.
The court dismissed the claims for damages and declaratory relief without prejudice and transferred the habeas claims seeking release, restoration of good-time credit, and a medical transfer to the U.S. District Court for the District of Colorado; it left the transferee court to decide whether the medical-transfer claim survives under Tenth Circuit law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether damages and declaratory relief are proper in §2241 habeas	Dyson seeks money and a declaration that respondents violated his religious rights	Respondents contend habeas cannot award damages or declaratory relief about past constitutional violations	Dismissed without prejudice: damages and declaratory claims not cognizable in habeas; separate civil action required
Whether habeas is proper forum for relief that would affect duration of custody	Dyson seeks release and restoration of good-time credits via §2241	Respondents contend habeas must be filed in district of confinement	Transfer: these habeas claims must be heard in the district of confinement (District of Colorado)
Whether D.C. court has territorial jurisdiction over custody-related habeas	Dyson filed in D.C. despite being confined in Colorado	Respondents argue territorial-jurisdiction requirement bars D.C. adjudication	Court lacks territorial jurisdiction and transfers the custody-related claims to Colorado
Whether a request for medical transfer/conditions of confinement may proceed in habeas	Dyson requests an injunction for a medical transfer/accommodation for disability	Respondents point to circuit split; Tenth Circuit treats transfer as conditions claim (Bivens), D.C. Circuit allows conditions in habeas	Court transfers the medical-transfer claim to Colorado and leaves to transferee court to apply its circuit law (may be governed by Tenth Circuit)

Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus unavailable for claims seeking damages or declaratory relief that do not affect immediate custody)
Rumsfeld v. Padilla, 542 U.S. 426 (2004) (habeas jurisdiction for present physical confinement lies in the district of confinement)
Braden v. 30th Judicial Cir. Ct. of Ky., 410 U.S. 484 (1973) (writ issues only against the custodian who has territorial control over the prisoner)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (relief that would necessarily imply the invalidity of confinement requires habeas)
Stokes v. U.S. Parole Comm’n, 374 F.3d 1235 (D.C. Cir. 2004) (discussing territorial limits on habeas jurisdiction and custodial focus of the writ)
Aamer v. Obama, 742 F.3d 1023 (D.C. Cir. 2014) (D.C. Circuit recognizes a prisoner may challenge conditions of confinement in federal habeas)
Dhiab v. Trump, 852 F.3d 1087 (D.C. Cir. 2017) (conditions-of-confinement claims may be included in a habeas petition under D.C. Circuit precedent)
Davis v. U.S. Sentencing Comm’n, 716 F.3d 660 (D.C. Cir. 2013) (a damages claim that would imply invalidity of confinement cannot proceed absent success on related habeas)
United States v. Garcia, 470 F.3d 1001 (10th Cir. 2006) (Tenth Circuit treats requests for change in place of confinement as conditions claims, often requiring a Bivens action)