HOLLAND
v.
GABBY
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Federal inmate Justina Marina Holland sought habeas relief under 28 U.S.C. § 2241, claiming the Bureau of Prisons failed to award her all earned sentence credits. The district court adopted the magistrate judge's recommendation and denied relief on the merits without addressing the government's exhaustion argument.
Holland is not entitled to relief. The court adopted the magistrate judge's recommendation and denied the § 2241 petition on the merits without reaching the government's exhaustion argument, as exhaustion is not jurisdictional.
“exhaustion is not jurisdictional and that courts can deny relief on the merits without considering exhaustion”
Establishes the court's authority to address the merits of the habeas petition without first resolving the government's exhaustion defense
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Join FLexlaw to unlock all legal intelligenceHolland is a federal inmate who petitioned for § 2241 habeas relief, claiming she did not receive all sentence credits to which she was entitled under…
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Federal inmate Justina Marina Holland petitioned for § 2241 relief. Her claim is that the Bureau of Prisons has not provided all credits to which she is entitled. The government filed a response asserting lack of exhaustion and arguing-exhaustion aside-Holland is not entitled to relief. The magistrate judge issued a thorough report and recommendation concluding Holland has not shown entitlement to any relief. ECF No. 14. I have carefully considered that report and recommendation, and I have carefully considered de novo the issues Holland raised in her objections (ECF No. 15).
I agree with the magistrate judge: Holland has not shown entitlement to relief. I do not address the exhaustion issue. See Santiago-Lugo v. Warden, 785 F. 3d 467, 475 (11th Cir. 2015) (noting that exhaustion is not jurisdictional and that courts can deny relief on the merits without considering exhaustion). I now adopt the report and recommendation and incorporate it into this order.
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The clerk will enter a judgment that says, "The § 2241 petition is denied." The clerk will then close the file.
SO ORDERED on May 1, 2025.
s/ Allen Winsor United States District Judge
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