Hill v. Bradley, 3:21-cv-02036

Petitioner Sheldon W. Hill is a federal inmate at USP-Canaan serving a 151‑month sentence for bank robbery with a projected GCT release date of May 9, 2025.
On April 15, 2020, Hill requested compassionate release or transfer to home confinement due to COVID‑19; the Warden denied the request on April 23, 2020.
Hill did not pursue the BOP administrative appeal process after the Warden’s denial and admits he failed to exhaust administrative remedies.
Hill filed a §2241 habeas petition seeking a court order directing placement in home confinement under the CARES Act, arguing exhaustion should be excused (futility/statutory question/irreparable harm).
The Government argued Hill failed to exhaust and that BOP home‑confinement decisions are not judicially reviewable; the court dismissed the petition for lack of jurisdiction and for failure to exhaust administrative remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hill was required to exhaust BOP administrative remedies before §2241	Exhaustion is excused as futile and the claim is primarily a statutory/constitutional issue needing immediate review	Hill admitted he did not exhaust; BOP process must be completed; exhaustion serves agency expertise and judicial efficiency	Court: exhaustion required; Hill failed to exhaust; dismissal on that ground
Whether the court may order home confinement under the CARES Act	Court can direct relief under §2241 to secure placement in home confinement under CARES Act	BOP has exclusive statutory authority to designate place of imprisonment and CARES Act discretion rests with BOP; such decisions are committed to BOP and not reviewable by courts	Court: lacks authority to order home confinement under CARES Act/18 U.S.C. §3621(b)(5); dismissal for lack of jurisdiction

Moscato v. Federal Bureau of Prisons, 98 F.3d 757 (3d Cir. 1996) (prisoner must exhaust administrative remedies before §2241)
Bradshaw v. Carlson, 682 F.2d 1050 (3d Cir. 1981) (federal prisoner ordinarily must exhaust administrative remedies)
Arias v. United States Parole Comm’n, 648 F.2d 196 (3d Cir. 1981) (exhaustion requirement for federal prisoners)
Woodford v. Ngo, 548 U.S. 81 (2006) (proper exhaustion requires compliance with agency procedural rules)
Jones v. Bock, 549 U.S. 199 (2007) (proper exhaustion defined by applicable prison requirements)
Lyons v. United States Marshals, 840 F.2d 202 (3d Cir. 1988) (futility can be a narrow exception to exhaustion)
United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (strict exhaustion required during COVID‑19; BOP expertise and processes emphasized)