Background
Willie Davis, a federal prisoner, challenged the Bureau of Prisons’ authority to discipline him and revoke his earned good conduct time. Davis argued that Section 4042(d) of Title 18 exempts correctional institutions from Bureau of Prisons control, claiming the Administrative Maximum Facility fell under this exemption. The district court rejected this reading, finding the statute clearly limits the exemption to military or naval institutions only.
The court’s reasoning
The court applied de novo review to the statutory interpretation of 18 U.S.C. Section 4042. It concluded that the plain language of Section 4042(d) is unambiguous, with the words military and naval serving as adjectives modifying the phrase penal or correctional institutions. The court rejected Davis’s argument that the second or in the statute created a disjunctive reading that would exempt all correctional institutions. The court found that such a reading would render the terms military and naval meaningless. The court also addressed the petitioner’s reliance on Loper Bright, noting that the district court did not afford binding deference to the government’s view but performed its own independent statutory analysis.
What it means going forward
Federal prisoners at the Administrative Maximum Facility remain subject to Bureau of Prisons disciplinary programs that can reduce earned good conduct time credits. The ruling clarifies that the Bureau of Prisons retains management authority over all non-military federal correctional institutions.