Martinez v. Federal Prison Camp, 8:25-cv-03537

Eduardo U. Martinez, a federal prisoner at FCI Edgefield, filed a pro se habeas petition under 28 U.S.C. § 2241 to challenge the Bureau of Prisons' refusal to apply First Step Act (FSA) time credits to his sentence.
Martinez alleges that he lost his FSA credits and eligibility for halfway house placement/home detention without being found guilty by a Disciplinary Hearing Officer ( DHO).
The court notes Martinez was sanctioned after a travel error (incorrect airline ticket date) and subsequent return to custody, despite his efforts to resolve the situation and lack of formal DHO findings.
Martinez sought emergency injunctive relief to restore his FSA credits and halfway house placement while his petition is pending.
The petition was brought before the court before Martinez fully exhausted the internal Bureau of Prisons administrative remedy process, though he had commenced it.
The magistrate judge recommends denial of the injunctive relief motion, largely based on Martinez’s failure to exhaust administrative remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to FSA credits and halfway house placement	Martinez lost credits/opportunity without a DHO hearing, violating his rights.	Remedies not exhausted; procedural steps incomplete.	Denied; failure to exhaust administrative remedies.
Preliminary injunction standard	Without relief, further irreparable harm will occur; likely to succeed on merits.	Did not satisfy Winter factors, especially success on merits or exhaustion.	Denied; not likely to succeed on merits, Winter not satisfied.
Administrative exhaustion requirement	Initiated grievance; relief should not hinge on full exhaustion due to urgency.	Full exhaustion is mandatory before court review of sentence computation.	Denied; exhaustion required, not done.
Restoration of placement and credits	Court should compel BOP to restore status immediately.	No proper factual record developed due to incomplete exhaustion.	Denied; BOP entitled to agency process first.

Estelle v. Gamble, 429 U.S. 97 (pro se pleadings are to be liberally construed)
Preiser v. Rodriguez, 411 U.S. 475 (habeas corpus is the proper mechanism for challenging custody legality/duration)
Rumsfeld v. Padilla, 542 U.S. 426 (proper respondent and venue for habeas corpus under § 2241)
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (standard for preliminary injunctive relief)
Jones v. Bock, 549 U.S. 199 (purpose and importance of administrative exhaustion in prisoner suits)
Haines v. Kerner, 404 U.S. 519 (lenient standard for pro se pleadings applies, but not a shield against summary dismissal)