Case Explained: Davis v. Baysore

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-07-16

Docket: 1:25-CV-00156-STV)

The Tenth Circuit affirmed the district court’s denial of Willie Davis’s habeas corpus application under 28 U.S.C. § 2241, rejecting his claim that the Bureau of Prisons (BOP) lacked authority to discipline him and revoke his earned good conduct time (GCT). The court held that Davis was not entitled to relief because the statutory exemption in 18 U.S.C. § 4042(d), which states that Section 4042 “shall not apply to military or naval penal or correctional institutions,” does not exempt federal civilian prisons like the United States Penitentiary Administrative Maximum Facility (ADX). The court applied a de novo standard of review to the district court’s legal conclusions regarding statutory interpretation. Relying on traditional tools of statutory construction, the panel determined that the plain language of § 4042(d) is unambiguous: the adjectives “military” and “naval” modify the noun phrase “penal or correctional institutions.” Consequently, the exemption applies only to military or naval facilities, not to all federal correctional institutions. The court reasoned that Davis’s alternative reading would render the words “military” and “naval” meaningless, violating the principle that every word in a statute must be given effect. Furthermore, the court found no error in the district court’s reliance on the government’s interpretation, clarifying that *Loper Bright Enterprises v. Raimondo* does not prohibit courts from considering agency views or agreeing with them after independent analysis. As a result of this decision, Davis’s request for the restoration of 675 days of GCT and immediate release was denied. The judgment confirms the BOP’s authority to administer its disciplinary program and revoke GCT credits under 18 U.S.C. § 4042(a)(3). Davis remains confined at ADX and is scheduled for release in January 2027, subject to the forfeiture of his earned time credits.

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