Steven Johnson v. Warden Canaan USP, 699 F. App'x 125

Steven A. Johnson, a federal inmate at USP Canaan, filed a § 2241 habeas petition alleging problems with the prison mail system: nonreceipt of magazine subscriptions and legal mail opened outside his presence and processed as regular mail.
The District Court dismissed the § 2241 petition without prejudice, reasoning Johnson challenged conditions of confinement, not the validity or execution of his sentence, and thus habeas relief was unavailable.
The District Court noted Johnson could pursue his claims in a civil rights action (Bivens) after exhausting administrative remedies under 42 U.S.C. § 1997e(a).
The dismissal was styled without prejudice but treated as immediately appealable because Johnson could not amend a § 2241 petition to cure the defect—he would need to file a different type of action.
Johnson appealed; the Third Circuit exercised plenary review and summarily affirmed the District Court’s dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2241 is a proper vehicle to challenge prison mail procedures	Johnson argued his mail claims (magazines, legal mail opened outside his presence) are cognizable under § 2241	The government argued these claims challenge conditions of confinement, not the execution/validity of the sentence, so habeas is improper	Court held § 2241 is not available; claims challenge conditions and must proceed, if at all, via civil rights action after exhaustion
Whether the District Court’s dismissal without prejudice was appealable	Johnson implicitly contended he could appeal the dismissal	The government implied dismissal was proper and dismissal was effectively final because amendment of § 2241 could not cure the defect	Court held dismissal was immediately appealable because Johnson could not amend a § 2241 to state a cognizable claim and would need a different action; summary affirmance

Woodall v. Fed. Bureau of Prisons, 432 F.3d 235 (3d Cir. 2005) (§ 2241 covers challenges to execution of sentence, not conditions)
Leamer v. Fauver, 288 F.3d 532 (3d Cir. 2002) (distinguishing conditions-of-confinement claims from execution-of-sentence challenges)
Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (permitting implied damages remedy against federal officers for constitutional violations)
Jones v. Block, 549 U.S. 199 (2007) (exhaustion requirement for Bivens/FTCA-type claims)
Lopez v. Davis, 531 U.S. 230 (2001) (example of § 2241 review when claim challenges execution-related prison regulations)
Okereke v. United States, 307 F.3d 117 (3d Cir. 2002) (standards for appellate review of habeas dismissals)
Deutsch v. United States, 67 F.3d 1080 (3d Cir. 1995) (when dismissal without prejudice is immediately appealable)