Maxwell v. Dinis

In 2020 Maxwell sought transfer to halfway house or home confinement under the First Step Act of 2018, 18 U.S.C. §3624(g), 18 U.S.C. §3621(b) and §3621(h), the CARES Act of 2020, 18 U.S.C. §3624(c), the Second Chance Act of 2018 reauthorized by the First Step Act of 2018, 34 U.S.C. §60541, and Compassionate Release. The Warden only addressed Maxwell's CARES Act request and denied relief. The warden otherwise ignored all Maxwell's other explicitly pled issues. Maxwell, after exhausting his administrative remedies proceeded in Court, filing a §2241 habeas. The U.S.D.C. dismissed alleging Maxwell failed to exhaust his administrative remedies for First Step Act relief. Maxwell appealed the decision of the U.S.D.C. to the Fifth Circuit. Sua sponte , the Fifth Circuit held, contrary to this Court ’ s decision in Jones v. Hendrix , 216 L.Ed.2d 471, 484 (2022), and contrary to nine other Courts of Appeal -- see Woodall v. Fed. Bureau of Prisons , 432 F.3d 235, 241 (3d Cir. 2025); Jiminian v. Nash , 245 F.3d 144, 147 (2d Cir. 2001); Hernandez v, Campbell , 204 F.3d 861, 864 (9th Cir. 2000); United States v. Hutchins , 835 F.2d 185, 186 (8th Cir, 1987); Montez v. McKinna , 208 F.3d 862, 865 (10th Cir. 2000); United States v. Little , 392 F.3d 671, 678- 79 (4th Cir. 2024); McCarthan v. Dir. of Goodwill Indus. - Suncoast , 851 F.3d 1076, 1092-93 (11th Cir. 2007) ( en banc ); United States v. Barrett , 178 F.3d 34, 50 n.10 (1st Cir. 1999); and Valona v. United States , 138 F.3d 693, 694 (7th Cir. 1998) --that its bright-line rule adopted in Melot v. Bergomi , 970 F.3d 596, 599 (5th Cir. 2020) controlled. There the Fifth Circuit held that unless a favorable determination of the prisoner's claim would not automatically entitle him to accelerated release from his sentence, then the proper vehicle is a civil rights suit. The Fifth Circuit dismissed. I. The question for this Court is whether disputes regarding the calculation of an inmate's earned First Step Act time credits, enabling the inmate to transfer into halfway house or home confinement earlier, similar to parole, are actionable under 28 U.S.C. §2241, II. The question for this Court is whether, given all the obstruction of the administrative remedy process that took place in this case, under Perttu v. Richards , exhaustion of administrative remedies is interwoven into the underlying claims themselves, creating a fact issue for a jury, and whether the trial court must make that determination in the first instance

William Maxwell is a federal prisoner housed at FCI Beaumont Low in Texas. In 2020, Maxwell asked prison officials to transfer him to a halfway house or home confinement, invoking several laws including the First Step Act's earned time credit provisions, which require the Bureau of Prisons (BOP) to apply credits prisoners earn through participation in rehabilitation programs toward earlier placement in prerelease custody. The BOP responded only to Maxwell's request under the separate CARES Act and denied it, ignoring his First Step Act arguments entirely. After Maxwell pushed through the BOP's administrative grievance process — a process he contends the BOP actively obstructed by losing filings, failing to respond, and submitting a false declaration claiming he never raised First Step Act claims — he filed a federal habeas corpus petition under 28 U.S.C. § 2241 seeking transfer to a halfway house or home confinement based on his earned First Step Act time credits. The district court dismissed Maxwell's petition, ruling he had failed to exhaust his administrative remedies on his First Step Act claims. Maxwell appealed to the U.S. Court of Appeals for the Fifth Circuit, which sua sponte affirmed dismissal on a different ground — holding under its own bright-line rule that because a favorable ruling would not automatically accelerate Maxwell's release from prison, a civil rights lawsuit, not a habeas petition, was the only proper vehicle for his claims.