Riggall v. Healy
4:25-cv-00560
| N.D. Ohio | Jun 3, 2025Background
- Richard Milton Riggall, a federal prisoner, filed a pro se habeas corpus petition under 28 U.S.C. § 2241.
- Riggall challenges the Bureau of Prisons' (BOP) denial of his placement in a residential re-entry center under the Second Chance Act, 18 U.S.C. § 3624.
- Riggall contends he fully satisfied the requirements for pre-release placement, including maintaining good conduct and completing required programming, and that the assistant warden recommended his placement.
- The BOP allegedly delayed his re-entry placement, extending his release by nearly a year, without providing a valid reason or documenting its decision.
- Riggall admits he did not exhaust BOP’s administrative remedies, asserting that the lengthy process would render his claim moot given his short remaining sentence.
- The court reviewed the petition under the less stringent standards for pro se litigants, and considered whether exhaustion could be excused due to futility or urgency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of administrative remedies | No time to exhaust; process would be futile/moot before release | Must complete administrative process | Exhaustion required; no futility or urgency excused |
| Due process in denying re-entry placement | BOP denied placement w/o justification, violating due process | N/A | Not reached; dismissed for failure to exhaust |
Key Cases Cited
- Rice v. White, 660 F.3d 242 (6th Cir. 2011) (Section 2241 allows habeas relief for federal prisoners in violation of law)
- Urbina v. Thoms, 270 F.3d 292 (6th Cir. 2001) (pro se habeas petitions are construed liberally)
- Hilton v. Braunskill, 481 U.S. 770 (1987) (district courts may summarily dismiss meritless habeas petitions)
- Hartsfield v. Vidor, 199 F.3d 305 (6th Cir. 1999) (inmates cannot bypass or abandon administrative remedies to claim exhaustion)
- McCarthy v. Madigan, 503 U.S. 140 (1992) (exhaustion may only be excused in rare cases of futility or irreparable harm)
- Rose v. Lundy, 455 U.S. 509 (1982) (exhaustion of remedies is excused only in exceptional circumstances)