Wint v. Warden
3:24-cv-02500
S.D. Ill.Apr 14, 2025Background
- Daron Wint, serving four life sentences without release for first degree murder, filed a § 2241 habeas petition while incarcerated at FCI-Marion.
- Wint challenged the loss of good conduct credit due to prison disciplinary infractions and, more importantly, his resulting placement in the Communications Management Unit (CMU), which restricts inmate communications.
- Wint was transferred during the pendency of the petition but remained in a CMU at the new facility; the court noted this did not affect its jurisdiction.
- Wint argued that the disciplinary findings lacked evidentiary support and that his due process rights were violated in the proceedings leading to the disciplinary convictions and CMU placement.
- The respondent contended that Wint failed to exhaust administrative remedies, § 2241 was inappropriate for his claims, and there was no due process violation.
- The court examined whether § 2241 was a proper vehicle for challenging CMU placement versus challenging the duration or fact of confinement.
Issues
| Issue | Wint's Argument | Sproul's Argument | Held |
|---|---|---|---|
| Availability of § 2241 for relief | § 2241 suitable since CMU placement restricts liberty | § 2241 cannot challenge conditions, only duration/fact | § 2241 not available for this relief |
| Loss of good time credit | Acquittal of some charges requires acquittal of others | No due process violation occurred | Not addressed (moot due to life term) |
| Due process in disciplinary findings | Findings lacked evidence; due process was violated | Disciplinary process met requirements | Not addressed (relief type improper) |
| Recharacterization as Bivens action | Sought habeas relief, not civil rights action | N/A | No recharacterization by court |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (U.S. 1973) (habeas petitions appropriate for challenges to fact or duration of confinement)
- Graham v. Broglin, 922 F.2d 379 (7th Cir. 1991) (distinguishes between quantum change in custody and conditions of confinement for § 2241)
- Walker v. O’Brien, 216 F.3d 626 (7th Cir. 2000) (§ 2241 limited to challenges to custody level; general principles on habeas applicability)
- Bunn v. Conley, 309 F.3d 1002 (7th Cir. 2002) (transfer or custody changes within prison not addressable via § 2241)
- Rumsfeld v. Padilla, 542 U.S. 426 (U.S. 2004) (jurisdiction persists despite inmate transfer in habeas proceedings)
- Bivens v. Six Unknown Named Agents of the Fed. Bureau of Narcotics, 403 U.S. 388 (U.S. 1971) (civil rights claims for constitutional violations by federal officers)