Background
Ruben Plaza-Uzeta was sentenced to life imprisonment in 2007. During his incarceration, he was found guilty of possessing dangerous weapons in 2010 and 2021, resulting in disciplinary sanctions that reduced his good conduct time credits by 81 days. In 2022, he was resentenced to 360 months. The Bureau of Prisons calculated his release date based on the original 2007 start date, applying credits for time served and deducting the 81 days for sanctions. Plaza-Uzeta filed a petition under 28 U.S.C. Section 2241, arguing the Bureau lacked authority to sanction a life-sentenced prisoner with loss of good conduct time.
The court’s reasoning
The court reviewed the denial of the habeas petition de novo. It held that a habeas claim cannot be sustained based solely on a violation of a Bureau of Prisons program statement. The court found the Bureau of Prisons properly recalculated the sentence under 18 U.S.C. Section 3585 and applied 18 U.S.C. Section 3624(b)(1) to award good conduct time credits while also disallowing credits for disciplinary violations. The court concluded this application was a straightforward and logical reading of the statute. The court declined to review a due process claim raised for the first time on appeal.
What it means going forward
The decision confirms that the Bureau of Prisons retains authority to reduce good conduct time credits for disciplinary infractions regardless of whether an inmate is serving a life sentence or a fixed term, provided the calculation follows statutory guidelines.
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