Kevin Kerr v. Warden Allenwood USP, 21-2029

Kevin Kerr, a pro se prisoner serving a life sentence, was committed to a federal medical center for mental-health treatment under 18 U.S.C. § 4245.
Kerr filed a 28 U.S.C. § 2241 habeas petition challenging: the commitment order; alleged violations of his religious/free-exercise rights (claiming a right to “represent himself” tied to his religious name); and the validity of his conviction based on incompetence and due-process violations.
The District Court dismissed the petition: it held challenges to the conviction belong in a § 2255 motion; claims about conditions or civil rights belong in a Bivens action; and although a § 2241 challenge to a § 4245 commitment can be cognizable, Kerr was lawfully confined.
Kerr appealed; he filed an appellate brief that the court found failed to identify errors in the district-court ruling and included baseless/religious-themed arguments.
The Third Circuit reviewed independently and concluded Kerr had no arguable basis in law or fact for relief under § 2241 and dismissed the appeal as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can civil-rights/conditions claims be pursued via habeas (§ 2241)?	Kerr raised civil-rights-type claims about his confinement and treatment.	Such claims do not challenge the fact or duration of custody and must proceed in a civil action (e.g., Bivens), not habeas.	Habeas is unavailable for civil-rights/conditions claims; pursue Bivens or other civil remedies.
Can Kerr attack his underlying conviction/sentence via § 2241?	Kerr contended his conviction is invalid due to incompetence and due-process violations.	Challenges to conviction/sentence are presumptively brought under § 2255; Kerr did not show the narrow § 2241 escape hatch applies.	Dismissed: § 2255 is the proper vehicle; Kerr failed to meet exceptions permitting § 2241 relief.
Is Kerr’s § 4245 commitment invalid or subject to habeas relief now?	Kerr argued the commitment order should be set aside.	The commitment was lawful; Kerr did not meaningfully show error at issuance or a basis to lift it now.	Even if § 2241 can reach § 4245 commitments, Kerr failed to demonstrate entitlement to relief.
Should the appeal be dismissed as frivolous under § 1915(e)(2)(B)(i)?	Kerr’s appellate brief advanced essentially incoherent or baseless claims without identifying district-court errors.	The appeal lacks any arguable basis in law or fact and meets the frivolous standard.	The Third Circuit dismissed the appeal as frivolous.

Neitzke v. Williams, 490 U.S. 319 (establishes frivolous-pleading standard for in forma pauperis dismissals)
Preiser v. Rodriguez, 411 U.S. 475 (habeas bars challenges that are actually civil-rights claims about conditions)
Okereke v. United States, 307 F.3d 117 (motions under § 2255 are the presumptive means to attack federal convictions and sentences)
In re Dorsainvil, 119 F.3d 245 (narrow exception allowing § 2241 to challenge conviction when § 2255 is inadequate or ineffective)
Bruce v. Warden Lewisburg USP, 868 F.3d 170 (discusses the narrow circumstances permitting § 2241 to challenge convictions)
Archuleta v. Hedrick, 365 F.3d 644 (recognizes § 2241 may be used to challenge certain commitment orders)
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (provides a cause of action for certain constitutional torts by federal officials)
Reese v. Warden Phila. FDC, 904 F.3d 244 (no certificate of appealability required to appeal dismissal of a § 2241 petition)