Leonidas Fields v. Warden Allenwood USP
684 F. App'x 121
| 3rd Cir. | 2017Background
- Leonidas Fields, serving life for murdering a federal corrections officer (convicted in 1975), filed a § 2241 habeas petition in 2015 seeking an end to hourly security checks, compassionate release, and parole.
- District Court dismissed the petition: ordered security-check claims pursued as a civil-rights action; held it lacked jurisdiction to order compassionate release; and upheld the Parole Commission’s denial of parole.
- District Court reasoned security checks did not affect sentence duration nor conflict with the sentencing judgment.
- District Court concluded the Bureau of Prisons (BOP) exclusively controls filing motions for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), making that decision nonjusticiable.
- On parole, the District Court (assuming § 4206(d) might apply) found the Parole Commission acted rationally in denying mandatory parole by relying on Fields’s prison homicide as a serious institutional violation.
- Fields appealed and sought appointed counsel; the panel summarily affirmed and denied counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper vehicle for challenging hourly security checks | Fields: § 2241 can challenge conditions (security checks) | Gov: Conditions claims belong in § 1983/civil-rights actions unless they affect sentence execution/duration | District Court and panel: Not cognizable under § 2241; civil-rights action appropriate |
| Judicial review of compassionate-release denial | Fields: Court should order release or consider request | Gov: Only BOP Director may file § 3582(c)(1)(A)(i) motion; BOP decision is nonjusticiable | District Court and panel: No jurisdiction to grant relief; BOP controls filing, courts generally cannot review that decision |
| Denial of mandatory parole under former § 4206(d) | Fields: Parole denial was unlawful; he was entitled to mandatory parole | Gov: Parole Commission reasonably relied on serious institutional violation (homicide) and followed regulations | District Court and panel: Even assuming statute applies, denial was not an abuse of discretion; rational basis existed |
| Judicial bias / request for counsel on appeal | Fields: District Judge biased; requests counsel for appeal | Gov: No bias; appointment of counsel not warranted | Panel: No evidence of bias; request for appointed counsel denied |
Key Cases Cited
- Cardona v. Bledsoe, 681 F.3d 533 (3d Cir.) (limits § 2241 to challenges affecting execution/duration of sentence or conflicting with sentencing judgment)
- Leamer v. Fauver, 288 F.3d 532 (3d Cir.) (conditions-of-confinement claims are properly pursued under civil-rights actions when relief would not alter sentence)
- Cradle v. United States ex rel. Miner, 290 F.3d 536 (3d Cir.) (standards of review for § 2241 appeals)
- Furnari v. Warden, Allenwood Fed. Corr. Inst., 218 F.3d 250 (3d Cir.) (courts may review parole denials for rational basis and regulatory compliance)
- Gambino v. Morris, 134 F.3d 156 (3d Cir.) (limitations and scope of judicial review of Parole Commission decisions)
- Fernandez v. United States, 941 F.2d 1488 (11th Cir.) (BOP’s decision to file compassionate-release motion is generally not judicially reviewable)