The opinion
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
RENALDO MEADOWS, Civil No. 3:24-cv-952
Petitioner □ (Judge Mariani)
v. .
WARDEN, FCI-ALLENWOOD LOW,
Respondent .
MEMORANDUM
Petitioner Renaldo Meadows (“Meadows”) initiated the above-captioned action by
filing a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241, alleging that the
Federal Bureau of Prisons (“BOP”) incorrectly calculated and applied his earned time credits
under the First Step Act (“FSA”). (Doc. 1). For the reasons that follow, the Court will
dismiss the habeas petition without prejudice based on Meadows’ failure to exhaust the
available administrative remedies.
Background
Meadows is serving a 188-month term of imprisonment imposed by the United
States District Court for the Eastern District of North Carolina for his conviction of narcotics
related offenses. (Doc. 8-3). His current projected release date is December 10, 2024.
(Id.).
The Administrative Remedy Generalized Retrieval reveals that, while in BOP
custody, Meadows filed a total of eight administrative remedies. (Doc. 8-4). Only one of
those administrative remedies—number 1201875—pertains to FSA time credits. (/d. at p.
6). On June 6, 2024, Meadows filed Administrative Remedy Number 1201875-F 1 at the
institution level regarding FSA time credits. (/d.). Also on June 6, 2024, the remedy was
closed. (/d.). Meadows filed an appeal to the regional level, designated as Administrative
Remedy Number 1201875-R1. (/d.). The Regional Office accepted his appeal, and has
until September 3, 2024 to address the appeal. (/d.).
In his § 2241 petition, Meadows alleges that he is entitled to 365 days of earned time
credits under the FSA towards his release date, or 285 days of earned time credits under
the FSA towards Residential Reentry Center/Home Confinement placement. (Doc. 1, p. 7).
Respondent counters that the § 2241 petition must be dismissed based on Meadows’ failure
to exhaust his administrative remedies before proceeding to federal court. (Doc. 8).
Alternatively, Respondent seeks dismissal on the following grounds: (1) the BOP properly
calculated Meadows’ FSA time credits; and (2) Meadows has no right to prerelease
custody. (/d.). Because the record clearly establishes that Meadows failed to fully exhaust
his administrative remedies, the Court does not reach Respondent's alternative arguments.
Il. Discussion
Although there is no explicit statutory exhaustion requirement for § 2241 habeas
petitions, the United States Court of Appeals for the Third Circuit has consistently held that
exhaustion applies to such claims. See Callwood v. Enos, 230 F.3d 627, 634 (3d Cir. 2000)
(citing Schandelmeier v. Cunningham, 819 F.2d 52, 53 (3d Cir. 1986)); Moscato v. Fed.
Bureau of Prisons, 98 F.3d 757, 760 (3d Cir. 1996). Exhaustion allows the relevant agency
to develop a factual record and apply its expertise, conserves judicial resources, and
provides agencies the opportunity to “correct their own errors” thereby fostering
“administrative autonomy.” Moscato, 98 F.3d at 761-62 (citations omitted). The Bureau of
Prisons has a specific internal system through which federal prisoners can request review of
nearly any aspect of their imprisonment. See generally 28 C.F.R. §§ 542.10-.19. That
process begins with an informal request to staff and progresses to formal review by the
warden, appeal with the Regional Director, and—ultimately—final appeal to the General
Counsel. See id. §§ 542.13-.15. No administrative remedy appeal is considered fully
exhausted until reviewed by the General Counsel. /d. § 542.15(a).
Exhaustion is the rule in most cases, and failure to exhaust will generally preclude
federal habeas review. See Moscato, 98 F.3d at 761. Only in rare circumstances is
exhaustion of administrative remedies not required. For example, exhaustion is
unnecessary if the issue presented is one that consists purely of statutory construction. See
Vasquez Vv. Strada, 684 F.3d 431, 433-34 (3d Cir. 2012) (citing Bradshaw v. Carlson, 682
F.2d 1050, 1052 (3d Cir. 1981)). Exhaustion is likewise not required when it would be futile.
Rose v. Lundy, 455 U.S. 509, 516 n.7 (1982).
Meadows’ Administrative Remedy Generalized Retrieval report demonstrates that he
failed to properly exhaust the claims in the instant habeas petition. (Doc. 8-4). On June 6,
2024, Meadows filed Administrative Remedy Number 1201875-F 1 at the institution level
regarding a request for FSA time credit. (/d. at p. 6). On that same date, the remedy was
closed. (Id.). Meadows then filed an appeal to the Regional Office on July 5, 2024,
designated as Administrative Remedy 201875-R1. (/d.). That appeal remains pending, and
per the Administrative Remedy Generalized Retrieval, the Regional Office has until
September 3, 2024 to respond. (See id.).
Meadows concedes that he did not exhaust administrative remedies with regard to
his FSA time credits and argues that exhaustion would be futile “[b]Jecause of time
limitations.” (Doc. 1, p. 3; Doc. 2). However, he has not articulated any basis for his
suggestion of futility. While the court recognizes that administrative exhaustion is not
required if “the issue presented only pertains to statutory construction,” Kurti v. White, No.
1:19-cv-2109, 2020 WL 2063871, at *3 (M.D. Pa. Apr. 29, 2020), the instant case involves a
dispute regarding the specific number of FSA time credits earned by Meadows. Meadows
is not challenging the legality of BOP regulations or presenting an issue of statutory
construction that might justify excusing him from the exhaustion requirement. He appears
to argue that he should not have to exhaust his administrative remedies because the
administrative remedy process could take months to complete, and he believes that he
should be released before the process is completed. (Doc. 2). The Court is unaware of any
decision from the Third Circuit Court of Appeals holding that a federal prisoner may be
excused from the exhaustion requirement on that ground. Additionally, district courts within
the Third Circuit have repeatedly rejected the argument that an inmate can be excused from
the exhaustion requirement simply because his projected release date is approaching, and
he may not complete his administrative appeal before the release date. See, e.g., Brown v.
Sage, No. 22-cv-325, 2022 WL 1295414, at *1-2 (M.D. Pa. April 29, 2022); Malvestuto v.
Martinez, No. 09-cv-1339, 2009 WL 2876883, at *2-3 (M.D. Pa. Sept. 1, 2009); Bartolotti v.
Knight, No. 22-cv-6137, 2022 WL 17959577, at *1-2 (W.D. Pa. Dec. 27, 2022); Rosales v.
Hollingsworth, No. 15-cv-3840, 2015 WL 4314572, at *2 (D.N.J. July 14, 2015). Meadows’
claim is the type of FSA time credit dispute that must first be presented to BOP officials and
fully exhausted. Because Meadows did not exhaust his administrative remedies, and no
exception applies, his § 2241 petition must be dismissed.
Ill. Conclusion
Based on the foregoing, the Court will dismiss the petition for writ of habeas corpus
filed pursuant to 28 U.S.C. § 2241. (Doc. 1). A separate Order shall issue.
)
( Val 4
Robert D. Mariani
ie United States District Judge
Dated: August Jf, 2024