Courtney Omar Boyd v. Warden, FCC Coleman-Low

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA OCALA DIVISION COURTNEY OMAR BOYD, Petitioner, v. Case No.: 5:25-cv-44-SPC-PRL WARDEN, FCC COLEMAN-LOW, Respondent. / OPINION AND ORDER Petitioner Courtney Omar Boyd, a federal prisoner at FCC Coleman, seeks a writ of habeas corpus directing the Bureau of Prisons (BOP) to release him immediately to a residential re-entry center or home confinement. Boyd, a Jamaican citizen, is subject to an immigration detainer lodged by the Department of Homeland Security. As a result of the detainer, the BOP has determined that Boyd is not eligible for placement in pre-release custody. For the reasons below, the Court agrees and dismisses Boyd’s petition.

I. Background Boyd is serving a 300-month sentence for controlled substance and money laundering offenses imposed in the United States District Court for the Eastern District of Virginia. See United States v. Boyd, No. 4:06-cr-5, Doc. 375 (E.D. Va. Sept. 20, 2021). His projected release date is January 10, 2027.1 Boyd is subject to an immigration detainer lodged against him by the Department of Homeland Security/Immigration and Customs Enforcement office on April 29, 2016.2 (Doc. 1 at 16).

In his petition, Boyd contends he is eligible to have both Second Chance Act (SCA) and First Step Act (FSA) credits applied towards his placement in a halfway house or home confinement, and for relief requests that the Court order the warden of his institution to award him 12 months of SCA credit and direct his immediate transfer to a halfway house or home confinement. (Doc.

1). The BOP has responded in opposition, asserting that the petition should be dismissed due to Boyd’s failure to exhaust administrative remedies or, alternatively, denied because Boyd lacks a liberty interest in his place of confinement and the Court is unable to provide the relief Boyd requests. (Doc.

II. Legal Standard A. Habeas Corpus The fundamental purpose of a habeas proceeding is to allow a person in custody to attack the legality of that custody, and the “traditional function of the writ is to secure release from illegal custody.” Preiser v. Rodriguez, 411 U.S. 475, 484 (1973). For example, when a prisoner makes a claim that, if successful, would invalidate his conviction or shorten his sentence, the claim must be brought as a habeas petition, not as a civil rights claim. See Edwards v. Balisok, 520 U.S. 641, 645–46 (1997); Heck v. Humphrey, 512 U.S. 477 (1994).

Conversely, a place-of-confinement claim is generally not cognizable in a habeas proceeding. Prerelease custody determinations are placement decisions committed to the discretion of the BOP. See 18 U.S.C. § 3624(c)(4) (“Nothing in this subsection shall be construed to limit or restrict the authority of the Director of the [BOP] under section 3621.”); 18 U.S.C. § 3621(b) (“Notwithstanding any other provision of law, a designation of a place of imprisonment under this subsection is not reviewable by any court.”). “The decision where to house inmates is at the core of prison administrators’ expertise.” McKune v. Lile, 536 U.S. 24, 39 (2002). Congress delegated to the BOP the authority to designate the place of a prisoner’s custody and enumerated five factors to consider. 18 U.S.C. § 3621(b) (“The [BOP] shall designate the place of the prisoner’s imprisonment[.])”.3 B. The Second Chance Act (SCA) and the First Step Act (FSA) The SCA authorizes the BOP to place a prisoner in a community correctional facility (also known as a Residential Reentry Center, RRC, or halfway house) or in home confinement to prepare for reentry into society prior to the expiration of the prisoner’s term of custody. See Second Chance Act of 2007, Pub. L. No. 110-199, 122 Stat. 657, § 251 (amending 18 U.S.C. § 3624(c)).

Generally, a prisoner is eligible to spend up to 12 months in prerelease custody at an RRC prior to the end of the sentence. 18 U.S.C. § 3624(c)(1). A prisoner is also eligible for a period of home confinement not to exceed “the shorter of percent of the term of imprisonment of that prisoner or 6 months.” 18 U.S.C. § 3624(c)(2).

The FSA created a risk-and-needs assessment system under which prisoners could earn incentives, including time credits to be applied toward placement in prerelease custody and toward early placement on supervised

Finally, 34 U.S.C. § 60541(a)(2) grants the BOP the discretion to offer a prisoner “the maximum allowable period in a community confinement facility” and other “such other incentives” as are considered appropriate—but it does not permit the BOP to reduce a prisoner’s term of imprisonment.

C. Exhaustion of Administrative Remedies Although exhaustion of administrative remedies is not a jurisdictional requirement in a § 2241 proceeding, “that does not mean that courts may disregard a failure to exhaust and grant relief on the merits if the respondent properly asserts the defense.” Santiago-Lugo v. Warden, 785 F.3d 467, 475 (11th Cir. 2015). A court, however, “may skip over the exhaustion issue if it is easier to deny . . . the petition on the merits without reaching the exhaustion question.” Id. III. Discussion The substantive issues4 presented in this case are “murky” and “hazy.”

See Woolsey v. Warden, No. 2:25-cv-137, 2025 WL 2598794, at *7 (M.D. Ala. Sept. 8, 2025) (“Determining what constitutes a challenge to the execution of a sentence—when its duration remains unchanged—is where things get murky.”); Woodall v. Fed. Bureau of Prisons, 432 F.3d 235, 242 (3d Cir. 2005) (“Still, the precise meaning of ‘execution of the sentence’ is hazy.”). Although this Court recognizes that other courts have found it within their authority to direct the BOP to transfer a prisoner to home confinement, this Court finds The Court determines that skipping over the exhaustion issue is appropriate. Santiago-Lugo, 785 F.3d at 475. that Boyd’s petition presents a conditions-of-confinement issue not cognizable in a habeas proceeding.5 Courts generally lack the authority to direct the BOP to place a prisoner in prerelease custody. See Sills v. FCI Talladega Warden, No. 22-12656, 2023 WL 1775725, at *3 (11th Cir. Feb. 6, 2023) (district court lacked authority to order the BOP to place the prisoner in home confinement); Touizier v. U.S. Att’y Gen., No. 21-10761, 2021 WL 3829618, at *2 (11th Cir. Aug. 27, 2021) (same). “Congress surely knew when it drafted the FSA that it had long ago granted the BOP broad discretion in designating where convicted individuals will serve out their sentences.” Crowe v. Fed. Bureau of Prisons, No. 24-cv- 3582, 2025 WL 1635392, at *23 (D.D.C. June 9, 2025) (citation omitted).

The Woolsey court recently stated that there does not appear to be “any on-point binding precedent supporting the argument that § 2241 does not confer jurisdiction for relief seeking placement in prerelease custody under the FSA.” 2025 WL 2598794, at *8. “It does not appear that the Eleventh Circuit has specifically addressed what statutory vehicle should be used by a federal prisoner to challenge where a federal sentence should be served for purposes

Id. at *9 (citing Francis v. Maloney, 798 F.3d 33, 36 (1st Cir. 2015); Levine v. Apker, 455 F.3d 71, 78 (2d Cir. 2006); and Woodall v. Fed. Bureau of Prisons, 432 F.3d 235, 243 (3d Cir. 2005). The Woolsey court ultimately found the latter authority more persuasive, noting that placement in a community confinement is unique compared to general prison placement. Id. at *10.

Having considered the split in authority, the Court finds the opinions of the Fifth and Eighth Circuits more persuasive. If the Court were to grant Boyd his requested relief, he would not be released from custody sooner.

Instead, he would simply serve the remainder of his term of imprisonment somewhere different—in home confinement or at an RRC, both of which are a form of prerelease custody. “Prerelease custody is part of a term of imprisonment.” Wessels v. Houden, 2023 WL 7169154, at *1 (D. Minn. June 22, 2023) (citing § 3624(c) and collecting cases). Any relief the Court could grant would not secure release from illegal custody or shorten Boyd’s term of imprisonment.6 The Court does not find the Eleventh Circuit’s unpublished opinion in United States v. Saldana persuasive. 273 F. App’x 845 (11th Cir. 2008).

Saldana involved prisoners seeking to have the district court lift a separation order so they could be confined in the same prison. The Eleventh Circuit stated that it “has considered an attack by a federal prisoner on his place of confinement to be relief sought pursuant to 28 U.S.C. § 2241.” Id. (citing Ledesma v. United States, 445 F.2d 1323, 1323–24 (5th Cir. 1971)). However, the Eleventh Circuit ultimately held that the district court lacked jurisdiction to consider their petitions because they were not confined in that district. Id. at *847. More persuasive is the more recent authority in Sills and Touzier, affirming district courts’ determinations that they lacked authority to order inmates’ placement in home confinement. See Touzier, 2021 WL 3829618, at *2 (“The main question we must determine in this appeal is whether the district court has the authority to order the BOP to return Touizer to home confinement. We hold that it does not.”); Sills, 2023 WL 1775725, at *3 (“We

Finally, there is generally no protected liberty interest in prerelease custody. See Sills, 2023 WL 1775725, at *3 (acknowledging Sills had no protected liberty interest in home confinement and thus was “not entitled to due-process-protections in relation to that decision.”). Thus, Boyd has no constitutional right to apply earned credits in a specific manner. See Greenholtz v. Inmates of Nebraska Penal & Corr. Complex, 442 U.S. 1, 7 (1979) (“There is no constitutional or inherent right of a convicted person to be conditionally released before the expiration of a valid sentence.”).

IV. Conclusion The Court determines that Boyd’s claims ultimately relate to the conditions of his confinement, not the execution of his sentence, and are therefore not redressable through a habeas proceeding.7 Accordingly, it is now ORDERED: 1. The petition (Doc. 1) is DISMISSED without prejudice for lack of jurisdiction.

2. The Clerk is DIRECTED to enter judgment, terminate any pending motions and deadlines, and close this case.

DONE AND ORDERED in Fort Myers, Florida on January 15, 2026.

, tit WOblatet he 7 UNITED STATES DISTRICT JUDGE SA: OCAP-2 Copies: All Parties of Record