Robinson v. Warden
3:24-cv-01167
D. Conn.Mar 11, 2025Background
- Janell Robinson, incarcerated at FCI Danbury, filed a pro se habeas petition under 28 U.S.C. § 2241, challenging the Bureau of Prisons’ (BOP) calculation of her time credits under the First Step Act (FSA) and failure to grant prerelease custody under the Second Chance Act (SCA).
- Robinson’s sentence was for conspiracy to commit mail and wire fraud, wire fraud, and conspiracy to commit extortion, originally 108 months, later reduced to 97 months.
- The BOP documented Robinson’s accrued FSA credits and determined her earliest eligibility for prerelease custody under both FSA and SCA.
- The BOP scheduled Robinson’s placement at a residential reentry center (RRC) to begin April 24, 2025, about six months earlier than the end of her prison term, rather than the full twelve months she sought.
- Robinson requested adjustment of her credits and release dates, as well as an emergency “enlargement” (conditional release) during the pendency of her habeas petition.
- The court appointed counsel, considered submissions by both sides, and denied Robinson's claims and motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Application of FSA Time Credits to Advance Release | Robinson seeks immediate application of her earned FSA credits to her release date | BOP properly calculated and applied FSA credits per statutory requirements | Petition not ripe; Robinson not yet eligible for full FSA credit application |
| Prerelease Custody under SCA | Robinson entitled to max 12 months in RRC under SCA | BOP has discretion over duration and timing of SCA prerelease custody | No enforceable interest in full 12 months; BOP discretion affirmed |
| Timeliness/Reduction of Custody | Delay and reduction in prerelease period violate statutory rights | Any delay/shorter period within BOP’s lawful discretion | No legal violation; claim denied |
| Provisional Release Pending Litigation | Seeks release/enlargement pending outcome | No extraordinary circumstances warrant provisional release | Denied as moot, given denial of petition |
Key Cases Cited
- Carmona v. U.S. Bureau of Prisons, 243 F.3d 629 (2d Cir. 2001) (clarifies that § 2241 is proper for challenging sentence execution, not validity)
- Levine v. Apker, 455 F.3d 71 (2d Cir. 2006) (section 2241 petitions may challenge conditions or calculations of confinement)
- Mapp v. Reno, 241 F.3d 221 (2d Cir. 2001) (enlargement/bail available only in extraordinary habeas cases)