Jackson v. Warden of the Federal Detention Center at SeaTac
2:24-cv-00547
W.D. Wash.Sep 13, 2024Background
- Tayan Jackson, a federal prisoner, filed a pro se habeas petition under 28 U.S.C. § 2241 in the Western District of Washington, challenging the Bureau of Prisons’ (BOP) failure to conduct required formal reviews of his placement in segregated housing (SHU).
- At filing, Jackson was incarcerated at FDC SeaTac in Washington but was soon transferred to FCI Victorville in California.
- Jackson alleged due process violations based on the BOP’s alleged noncompliance with 28 C.F.R. § 541.26, claiming this could affect his good time credits and release date.
- The government (Respondent) moved to dismiss or transfer for lack of jurisdiction, and argued Jackson's claim was not cognizable in habeas and was unexhausted.
- Jackson moved for an evidentiary hearing; the court addressed jurisdiction, exhaustion, and the sufficiency of the habeas claim in its recommendation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Court jurisdiction after petitioner transfer | Petitioner was confined within district at filing | Court lacks jurisdiction due to petitioner’s transfer | Court has jurisdiction; transfer irrelevant |
| Cognizability of conditions claim in habeas | BOP violated due process in SHU review, affecting release | Claim not cognizable; does not affect fact/duration of confinement | Not a true habeas claim; dismissal appropriate |
| Exhaustion of administrative remedies | Claimed prior attempts to file grievances | Did not exhaust BOP remedies re: SHU placement | Not exhausted; supports dismissal |
| Entitlement to evidentiary hearing | Requested hearing on SHU placement process | Not entitled, claim legally insufficient | No evidentiary hearing required |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (distinguishing habeas claims attacking fact/duration of confinement versus conditions)
- Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (conditions of confinement claims not cognizable in habeas)
- Francis v. Rison, 894 F.2d 353 (9th Cir. 1989) (court retains jurisdiction after petitioner’s transfer)
- Campbell v. Henry, 614 F.3d 1056 (9th Cir. 2010) (prison mailbox rule for habeas filing date)