Unreported / Non-Citable
Background
Jeffrey Batio, a federal prisoner serving a 96-month sentence imposed by the U.S. District Court for the Middle District of Florida in United States v. Batio, No. 1:16-cr-00425, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241 in the U.S. District Court for the Northern District of California, Case No. 26-cv-04160-CRB (PR). The sentence began on December 20, 2021. Batio challenged the Bureau of Prisons' execution of his sentence, specifically its calculation of earned time credit under the First Step Act and Second Chance Act. BOP applied good conduct time and calculated a release date of October 13, 2028, and calculated that he could be transferred to prerelease home confinement in April 2026. Batio alleged that his credits required a January 2024 transfer and that BOP's miscalculation caused 25 months of excess prison confinement and continued prerelease home confinement beyond the statutory endpoint.
On April 13, 2026, Batio was transferred to prerelease home confinement in San Jose, California, supervised by the Residential Reentry Manager (RRM) located in Sacramento, California. The court found the claim arguably cognizable under § 2241 and ordered the respondent, the RRM for the Northern District of California, to show cause why the writ should not be granted. The respondent instead moved to dismiss for lack of jurisdiction or, in the alternative, to transfer the petition to the Eastern District of California. Batio filed a response, the respondent filed a reply, and Batio also moved for leave to file a sur-reply (ECF No. 13), which the court considered and granted.
The Court’s Holding
The court held that it lacked habeas jurisdiction over the petition. Under 28 U.S.C. § 2241(a), district courts may grant writs of habeas corpus only within their respective jurisdictions, and the issuing court must have jurisdiction over the custodian, meaning the custodian must be within the court's territorial jurisdiction. A § 2241 petition challenging the execution of a federal sentence must therefore be brought in the custodial court, and a court lacks habeas jurisdiction if the custodian is outside its territorial limits; nationwide service of process does not cure that defect. RRM Sacramento supervises Batio's prerelease home confinement and is the relevant custodian, but because RRM Sacramento is outside the Northern District of California's territorial jurisdiction, the court lacked jurisdiction over the case.
Rather than dismissing the petition, the court applied 28 U.S.C. § 1631, which permits transfer in the interest of justice to a court in which the action could have been brought when filed. Because RRM Sacramento lies in the Eastern District of California under 28 U.S.C. § 84(b), the court ordered the petition transferred to the U.S. District Court for the Eastern District of California, directed the clerk to terminate as moot the motions appearing at ECF Nos. 9 and 13, and ordered the matter transferred forthwith.
Key Takeaways
- A federal prisoner challenging the Bureau of Prisons' calculation of earned time credits under § 2241 must file the habeas petition in the district with territorial jurisdiction over the prisoner's custodian.
- For a prisoner on prerelease home confinement, the relevant custodian is the Residential Reentry Manager supervising that confinement, not the district where the prisoner physically resides.
- RRM Sacramento supervises prerelease custody of federal prisoners in the Eastern District of California, the Northern District of California, the District of Hawaii, and the District of Guam.
- Lack of jurisdiction over the custodian is fatal to habeas jurisdiction and cannot be cured by nationwide service of process statutes.
- Under 28 U.S.C. § 1631, a court that lacks jurisdiction may transfer the petition to the proper district in the interest of justice instead of dismissing it; here the court also granted the sur-reply motion and terminated ECF Nos. 9 and 13 as moot.
Why It Matters
The order reinforces the strict territorial limits on habeas jurisdiction under 28 U.S.C. § 2241 and clarifies that for prisoners on prerelease home confinement the relevant custodian is the Residential Reentry Manager with supervisory authority, not the prisoner's physical location. It underscores that filing in the wrong district will result in transfer or dismissal regardless of the merits of the underlying time-credit claim.
The ruling also illustrates the procedural path available when a habeas petition is filed in the wrong district: under § 1631 the court may transfer the petition to the district with proper jurisdiction, preserving the petitioner's claim without requiring a new filing.