Letterlough v. Neely, 7:24-cv-00446

Nyree Letterlough filed a habeas corpus petition under 28 U.S.C. § 2241 seeking earned time credits under the First Step Act.
Letterlough was convicted of possession with intent to distribute cocaine and cocaine base, possession of a stolen firearm, and possession of a firearm in furtherance of a drug trafficking crime (18 U.S.C. § 924(c)(1)(A)).
Her sentence was initially 111 months; President Biden later commuted her prison term to 60 months, but this did not affect her First Step Act credits eligibility.
Letterlough objected to a magistrate judge’s finding that her § 2241 petition should be denied, arguing her § 924(c) conviction should not disqualify her from credits.
The core of her objection was whether her conviction constitutes a "crime of violence," allegedly impacting her eligibility for earned time credits.
The district court reviewed the objection and adopted the magistrate’s recommendation, denying the petition.

Issue	Letterlough's Argument	Neely's Argument	Held
Does a conviction under 18 U.S.C. § 924(c)(1)(A) disqualify Letterlough from First Step Act earned time credits?	It should not, as the conviction is not a crime of violence.	Statute excludes § 924(c) convictions related to drug trafficking, regardless of crime of violence status.	Court held Letterlough is ineligible for credits due to her conviction.
Can Letterlough challenge her conviction’s validity via § 2241?	Asserts possible innocence arguments regarding firearm possession and drug trafficking involvement.	§ 2241 is not proper for collateral attacks on conviction—only appropriate for sentence execution issues.	Court held conviction validity cannot be challenged under § 2241.
Does the commutation of Letterlough’s sentence affect her eligibility for earned time credits?	(No direct argument by Letterlough)	Commutation does not alter earned time credit eligibility under statute.	Court held commutation has no effect on eligibility.
Does the characterization of the offense as a “crime of violence” impact First Step Act credit eligibility?	Conviction should only disqualify if it's a crime of violence.	Statutory exclusion applies to drug trafficking crimes with firearms, independent of crime of violence label.	Court held eligibility does not depend on the crime of violence classification in this context.

McCarthan v. Dir. of Goodwill Indus.---Suncoast, Inc., 851 F.3d 1076 (11th Cir. 2017) (distinguishes proper use of § 2241 for execution of sentence, not for challenging sentences)
Antonelli v. Warden, U.S.P. Atlanta, 542 F.3d 1348 (11th Cir. 2008) (explains § 2241’s purpose is to challenge sentence execution, not conviction validity)