Aloba v. Warden

Federal inmate Temidayo Aloba filed a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2241 against the Warden of FCC Coleman in the U.S. District Court for the Middle District of Florida. Aloba claimed that the Bureau of Prisons improperly calculated his earned time credits under the First Step Act, which allegedly delayed his transfer to prerelease custody or supervised release. The court, through Magistrate Judge Philip R. Lammens, examined whether Aloba had exhausted the BOP's multi-tier administrative remedy process before seeking judicial intervention. Finding that Aloba failed to complete the required BP-8, BP-9, BP-10, and BP-11 grievance procedures, the court recommended dismissal of the petition without prejudice. The District Court adopted the recommendation, emphasizing that the exhaustion requirement is jurisdictional and serves to allow the agency to correct its own errors first.

The petition was dismissed without prejudice for failure to exhaust administrative remedies. Aloba was permitted to refile after properly completing the BOP grievance process.

Whether a federal prisoner must exhaust all available administrative remedies within the Bureau of Prisons before challenging the calculation of First Step Act earned time credits through a § 2241 habeas corpus petition.

The case reinforced the strict procedural barrier of administrative exhaustion in federal prison litigation, clarifying that even statutory rights under the First Step Act cannot bypass the BOP grievance system. It served as a cautionary precedent for inmates seeking expedited judicial relief without first allowing correctional authorities the opportunity to resolve computation disputes internally.