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Watkins v. Holland

United States District Court, Sixth Circuit

October 18, 2013

CARL WATKINS, Petitioner,
J.C. HOLLAND, Warden of FCI, Manchester, Respondent.


DANNY C. REEVES, District Judge.

Petitioner Carl Watkins is an inmate confined at the Federal Correctional Institution in Manchester, Kentucky ("FMC-Manchester"). Proceeding without counsel, Watkins filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. Through this action, he seeks to compel the Bureau of Prisons ("BOP") to recalculate his term of imprisonment. [Record No. 1] Watkins also filed a Motion to Compel the BOP to Comply with Judgment Order, in which he essentially reiterates the claims asserted in his § 2241 motion. [Record No. 16] Having reviewed Watkins' petition and motion to compel, the Court will deny the relief requested.


On February 1, 2010, Watkins was arrested by local law enforcement in Clayton County, Missouri. On February 4, 2010, while in state custody, a federal grand jury returned a three-count indictment against Watkins for robbery of federally insured institution in violation of 18 U.S.C. § 2113(a). [ United States v. Watkins, No. 4:10-CR-50-HEA (E.D. Mo. Feb. 4, 2010), Record Nos. 1, 2] On February 8, 2010, he was transferred into federal custody pursuant to a writ of habeas corpus ad prosequendum. [Record No. 16-1, p. 15] Watkins entered a written plea agreement on October 14, 2010. [ Watkins, No. 4:10-CR-50-HEA, Record Nos. 50, 51] And on February 22, 2011, he was sentenced to a 54-month term of incarceration. [ Id. at Record Nos. 64, 66]

On January 19, 2012, Watkins filed a motion with the district court seeking to be granted proper jail time credit. [ Id. at Record No. 95] Watkins indicated that on February 24, 2011 - two days after his federal sentence was imposed - the State of Missouri revoked his probation from a prior 2009 state conviction for theft of a credit card, and sentenced him to a three-year term of imprisonment to be served concurrently with his pre-existing federal term. [ Id. at Record No. 95-1, p. 8; see also Record No. 1-1, p. 1] During his state sentencing hearing, the state judge explained to Watkins that the Missouri Department of Corrections would take him into state custody to classify him, but would then later release him back into federal custody. [Record No. 16-1, p. 43] On July 14, 2011, the Missouri Department of Corrections released Watkins into federal custody. [Record No. 1-1, p. 1]


In conducting an initial review of habeas petitions pursuant to 28 U.S.C. § 2243, the Court must deny the relief sought "if it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief." Rule 4 of the Rules Governing § 2254 Cases in the United States District Courts (applicable to § 2241 petitions pursuant to Rule 1(b)). Because Watkins is not represented by an attorney, the Court evaluates his petition under a more lenient standard. Erickson v. Pardus, 551 U.S. 89, 94 (2007); Burton v. Jones, 321 F.3d 569, 573 (6th Cir. 2003). Thus, at this stage of the proceedings, Watkins' factual allegations are accepted as true and his legal claims are liberally construed in his favor.

Watkins's § 2241 petition does not articulate a legal or factual basis for the relief he requests.[1] [Record No. 1] Instead, he merely references various documents attached to his petition. These documents include a Form BP-230, dated February 27, 2012, that Watkins filed with the Mid-Atlantic Regional Office ("MARO"), apparently requesting credit against his federal sentence for time served in state custody. [Record No. 1-1, p. 4] On March 2, 2012, MARO denied his request pursuant to 18 U.S.C. § 3585(b). [ Id., p. 3] However, it construed the request as also seeking a nunc pro tunc designation pursuant to Barden v. Keohane, 921 F.2d 476 (3d Cir. 1991). [ Id., p. 2] MARO referred this request to the BOP's Designation and Sentence Computation Center for consideration. [ Id., p. 3] On July 24, 2013, the BOP's Central Office issued a decision regarding Watkins' request for sentencing credit and his construed request for relief under Barden. [Record No. 16-1, pp. 14-16] It concluded that the sentencing credit Watkins sought against his federal sentence was precluded because "[a] review of state records indicates [his] probation violation sentence was credited with time spent in custody from February 1, 2010." [ Id., p. 15] The Central Office also declined to authorize a retroactive designation under Barden. [2] [ Id., p. 16]

Watkins also filed an addendum to his § 2241 petition that assists in clarifying the nature of his claim. [Record No. 15] In the addendum, Watkins asserts that although he was arrested by local authorities on February 1, 2010, and placed in the St. Louis County Justice Center, he was "in fact" considered a "federal detainee" as of February 5, 2010 (the date of his federal writ of habeas corpus ad prosequendum ). [Record No. 15, p. 1] He contends that his argument is further supported by the requirement that his requests for medical care be pre-approved by the United States Federal Marshal Service. [ See Record No. 15-1, p. 5] Watkins argues that because he was in exclusive federal custody from February 5, 2010, he is entitled to credit against his federal sentence from that date. [Record No. 15, p. 1]


Calculation of a federal prisoner's sentence (including both its commencement date and any credits for custody before the sentence is imposed) is determined by federal statute:

(a)... A sentence to a term of imprisonment commences on the date the defendant is received in custody awaiting transportation to, or arrives voluntarily to commence service of sentence at, the official detention facility at which the sentence is to be served.
(b)... A defendant shall be given credit toward the service of a term of imprisonment for any time he has spent in official detention prior ...

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