Hernandez-Jimenez v. Warden
3:24-cv-00689
S.D. Miss.Jun 2, 2025Background
- Mauricio Hernandez-Jimenez was convicted in 2018 in the Eastern District of Michigan for drug conspiracy and possession charges.
- He is currently incarcerated at FCC Yazoo City, Mississippi.
- Hernandez-Jimenez filed a petition for writ of habeas corpus under 28 U.S.C. § 2241, claiming the Bureau of Prisons (BOP) failed to properly apply First Step Act time credits to his sentence.
- The BOP denied his administrative request regarding the credits, and Hernandez-Jimenez did not pursue further administrative appeals before filing this action.
- The government moved to dismiss the petition, arguing failure to exhaust administrative remedies; Hernandez-Jimenez did not file a reply.
- The magistrate judge reviewed the parties’ submissions and the exhaustion requirement under federal law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hernandez-Jimenez’s § 2241 petition should be heard given his failure to exhaust administrative remedies | BOP is wrongfully denying earned First Step Act credits; court intervention needed | Petitioner did not complete mandatory BOP grievance process before filing; petition is premature | Petition dismissed without prejudice due to failure to exhaust administrative remedies |
Key Cases Cited
- Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion requires use of all available remedies and compliance with applicable deadlines)
- Rourke v. R.G. Thompson, 11 F.3d 47 (5th Cir. 1993) (federal inmates must exhaust administrative remedies before seeking habeas relief under § 2241)
- Fuller v. Rich, 11 F.3d 61 (5th Cir. 1994) (outlining futility and other exceptions to exhaustion requirement)
- Broderick v. Chapman, [citation="364 Fed. App'x 111"] (5th Cir. 2010) (exceptions to exhaustion apply only in extraordinary circumstances)
