Unreported / Non-Citable
Background
Petitioner Jeffrey Batio, a federal prisoner serving a 96-month sentence from the Middle District of Florida, filed a habeas corpus petition under 28 U.S.C. § 2241 in the Northern District of California challenging the Bureau of Prisons' calculation of his earned time credits under the First Step Act and Second Chance Act. Batio alleged that BOP miscalculated his credits, resulting in 25 months of excess prison confinement and a delayed transfer to prerelease home confinement until April 13, 2026, rather than January 2024. At the time of filing, Batio was on prerelease home confinement in San Jose, California, supervised by the Residential Reentry Manager (RRM) based in Sacramento.
The court found Batio's claim arguably cognizable and ordered the respondent, the RRM for the Northern District of California, to show cause. Respondent moved to dismiss for lack of jurisdiction or, alternatively, to transfer the petition to the Eastern District of California, arguing that the RRM in Sacramento is the proper custodian and resides outside the Northern District's territorial jurisdiction. Batio filed a response and a motion for leave to file a sur-reply, which the court granted.
The Court’s Holding
The court held that it lacks habeas corpus jurisdiction under 28 U.S.C. § 2241 because the petitioner's custodian, the RRM in Sacramento, is located outside the territorial jurisdiction of the Northern District of California. Citing Rumsfeld v. Padilla and Ninth Circuit precedent, the court reaffirmed that a § 2241 petition must be brought in the district court with territorial jurisdiction over the custodian, and the nationwide service of process statute does not extend habeas jurisdiction beyond those limits.
Because RRM Sacramento supervises prerelease custody for the Eastern District of California, Northern District of California, District of Hawaii, and District of Guam, and is physically located in the Eastern District of California per 28 U.S.C. § 84(b), the court determined that transfer was appropriate. Exercising its authority under 28 U.S.C. § 1631 and following Hernandez v. Campbell, the court ordered the petition transferred to the United States District Court for the Eastern District of California in the interest of justice, terminating the pending motions as moot.
Key Takeaways
- A federal habeas petition under 28 U.S.C. § 2241 challenging the execution of a sentence must be filed in the district where the petitioner's immediate custodian is located.
- The Residential Reentry Manager supervising a prisoner on home confinement is the proper custodian for jurisdictional purposes.
- The Northern District of California lacks jurisdiction over a custodian based in Sacramento, which falls within the Eastern District of California.
- When a court lacks jurisdiction, 28 U.S.C. § 1631 permits transfer to the proper district in the interest of justice rather than dismissal.
- The court granted the petitioner's motion for leave to file a sur-reply before ruling on the transfer motion.
Why It Matters
This order clarifies the jurisdictional requirements for federal prisoners challenging BOP credit calculations while on prerelease home confinement. It confirms that the RRM, not the prisoner's physical location, determines the proper venue for a § 2241 petition. The decision reinforces Ninth Circuit precedent that habeas jurisdiction is strictly territorial and cannot be extended by nationwide service of process statutes. By transferring rather than dismissing, the court preserves the petitioner's claims for adjudication in the proper forum, ensuring that procedural defects do not bar review of potentially meritorious challenges to sentence execution.