Unreported / Non-Citable
Background
Daniel Alejandro Corral pleaded guilty to conspiracy to possess with intent to distribute more than five kilograms of cocaine after Border Patrol agents discovered 4.66 kilograms of cocaine in the vehicle he was driving. On January 5, 2026, he was sentenced to 64 months in prison followed by three years of supervised release.
While confined at FCI La Tuna, Corral filed a pro se petition under 28 U.S.C. § 2241 challenging the Bureau of Prisons’ calculation of his First Step Act earned time credits. Although the BOP calculated a March 2028 prerelease date, Corral asserted that his prerelease date should have been June 5, 2025—the day after his arrest and seven months before he was sentenced—and sought immediate release.
The Court’s Holding
The court dismissed the petition without prejudice at the initial-screening stage. It explained that the First Step Act permits eligible prisoners to earn credits through successful participation in qualifying programs and activities, but expressly bars prisoners from earning those credits during detention before their sentence commences.
Because Corral claimed entitlement to a prerelease date predating the commencement of his sentence, the court found his calculation clearly baseless. It concluded that the petition showed on its face that Corral could not establish that he was in custody in violation of federal law and therefore was not entitled to relief under § 2241.
Key Takeaways
- First Step Act earned time credits cannot be earned for programs completed before a federal sentence commences.
- A requested prerelease date that predates sentencing cannot be supported by First Step Act credits.
- A district court may summarily dismiss a § 2241 petition when the petition itself plainly establishes that the prisoner is not entitled to relief.
Why It Matters
The decision underscores the statutory starting point for earning First Step Act credits: credits accrue only after the prisoner’s sentence has commenced, not from the date of arrest or during presentence detention. It also illustrates that facially impossible credit calculations may be rejected during preliminary habeas review without further proceedings.