Steven Johnson v. Warden Lewisburg USP
694 F. App'x 59
| 3rd Cir. | 2017Background
- Steven Johnson, a federal prisoner proceeding pro se, filed a 28 U.S.C. § 2241 habeas petition challenging his placement in the Special Management Unit (SMU) at USP Lewisburg.
- Johnson alleged his custody classification was “medium,” which he said did not match SMU custody, and that the transfer was retaliatory for prior litigation.
- He sought a corrected custody classification and a transfer to a facility matching that classification.
- The District Court dismissed the § 2241 petition as not cognizable; Johnson appealed.
- After the District Court decision, Johnson was transferred to another institution; part of his requested relief (relating to Lewisburg SMU) became moot.
- The Third Circuit reviewed the matter de novo and affirmed the District Court, holding the remaining claim was not cognizable under § 2241.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson's challenge to SMU placement/custody classification is cognizable under 28 U.S.C. § 2241 | Johnson: placement in SMU with a "medium" custody classification and alleged retaliatory transfer are proper § 2241 habeas claims seeking corrective placement/transfer | Respondent: the claim does not challenge the execution or duration of the sentence and thus is not cognizable under § 2241 | Court: Not cognizable under § 2241; affirm dismissal |
| Whether Johnson's claims about confinement at USP Lewisburg SMU remain live | Johnson: seeks relief for SMU placement | Respondent: Johnson was transferred after the order, so SMU-related relief is moot | Court: SMU-related claims are moot to the extent they concern Lewisburg; remaining claim still not cognizable |
Key Cases Cited
- Cardona v. Bledsoe, 681 F.3d 533 (3d Cir. 2012) (explaining § 2241 cognizability depends on whether the claim affects execution/duration of sentence)
- Woodall v. Fed. Bureau of Prisons, 432 F.3d 235 (3d Cir. 2005) (permitting a § 2241 challenge where Bureau conduct conflicted with sentencing judgment)
- Jones v. Zenk, 495 F. Supp. 2d 1289 (N.D. Ga. 2007) (allowed a § 2241 challenge to BOP regulation limiting home confinement)