Easton v. Hall et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRJCT OF TEXAS
HOUSTON DIVISION
CHANELL RENEE EASTON, 	§
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Plaintiff,
VS.
TANISHA HALL, et al. ,
Defendants.
§ 	CIVIL ACTION NO. 4:25-CV-06338
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§
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MEMORANDUM AND ORDER
Federal prisoner Chanell Renee Easton (BOP #03091-510) filed this civil action
while in custody of the Bureau of Prisons ("BOP") at the Federal Prison Camp in Bryan,
Texas. 	Through counsel, she filed this complaint for declaratory and injunctive relief,
alleging that the BOP has delayed placing her in a residential program upon successful
completion of a Resident Drug and Alcohol Program ("RDAP") in violation of 18 U .S. C.
§§ 3621 , 3624(g), and 3632(d)(4). Doc. No. 1. Pending are Defendants' motion to dismiss
(Doc. No. 12) and Easton' s response in opposition with a motion for leave to amend (Doc.
No. 13). 	The Court has carefully reviewed the pleadings, attachments thereto, motions,
responses, and applicable law as follows.
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United States District Court
Southern District of Texas
ENTERED
July 23, 2026
Nathan Ochsner, Clerk
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I. 	BACKGROUND
Easton was convicted in the United States District Court for the Eastern District of
California and sentenced to 37 months' imprisonment for each of two counts of aggravated
identity theft in violation of 18 U.S.C. § 1028A(a)(l), and 24 months ' imprisonment on
each of 22 counts of wire fraud in violation of 18 U.S.C. § 1343, with the counts of wire
fraud to be served consecutively to the counts of identity theft, 	for a total term of
imprisonment of 61 months, special assessment of $2400, restitution of $361 ,099.54, and
36 months ' of supervised release. See Doc. No. 12-1 at 2-9 (Amended Judgment) ; United
States v. Easton, Crim. No. 2:22-cr-00103-1 (E.D. Cal. Feb. 28 , 2025). Easton claims that
while she was at the Bryan Federal Prison Camp, she completed the requirements and was
eligible for pre-release custody under the First Step Act of 2018, Pub. L. No. 115-391 , 132
Stat. 5194 (2018) ("FSA" ). 	Doc. No. 1 at 1-2. 	She alleges that she was confined in
institutional custody beyond the date she became eligible for pre-release custody and that
the BOP failed to apply statutory and its own directives in her case. 	Id. 	She invokes 18
U.S.C. §§ 3621 , 3624, and 3632 to argue that BOP "sha ll " transfer her to pre-release
custody upon the completion of her RDAP, which she completed in November 2025. 	Id.
at 2-3. In her pleadings, Easton specifically disclaims a Bivens 1 or habeas corpus cause of
action and seeks declaratory and injunctive relief under 28 U.S.C.§ 1331 to order the BOP
to assign her to pre-release custody. Doc. No. 1 at 3-4 & n.3.
1 Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971).
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The Defendants do not address the merits of this case and instead contend that
Easton's "freestanding" claims for injunctive relief fail because there is no independent
cause of action to support her claims for declaratory and injunctive relief. 	Doc. No. 12.
Easton requests leave to amend her complaint to add a claim under Bivens if her pleadings
are deficient. Doc. No. 13 at 9.
II. 	LEGAL STANDARDS
A. 	Prison Litigation Reform Act
Because Easton is a prisoner, the Prison Litigation Reform Act ("PLRA") applies
to this lawsuit. 	The PLRA requires, among other things, that a district court scrutinize
claims in a civil action brought by a prisoner and dismiss the complaint, in whole or in part,
if it " is frivolous , malicious, or fails to state a claim upon which relief may be granted;" or
"seeks monetary relief from a defendant who is immune from such relief." 	28 U.S.C.
§ 1915A(b).
B. 	Rule 12(b)(l)
Federal 	courts 	are 	"courts 	of limited jurisdiction, having 	' only 	the 	authority
endowed by the Constitution and that conferred by Congress. "' Halmekangas v. State Farm
Fire and Cas. Co ., 603 F.3d 290, 292 (5th Cir. 2010) (citations omitted). 	As such, the
existence of subject matter jurisdiction may be challenged at any stage in the litigation and
may be raised by the district court on its own motion. See Nguyen v. Dist. Dir., Bureau of
Immigration and Customs Enforcement, 400 F.3d 255 , 260 (5th Cir. 2005) (citations
omitted).
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Under Rule 12(b)(l), a party can seek dismissal of an action for lack of subject
matter jurisdiction. 	FED. R. CIV. P. 12(b )(1). 	The burden of establishing subject matter
jurisdiction is on the party seeking to invoke it. See Ramming v. United States, 281 F.3d
158 , 161 (5th Cir. 2001). 	When a Rule 12(b)(l) motion is filed along with other Rule 12
motions, the court should first consider the Rule l 2(b )( 1) motion. Id.
C. 	Rule 12(b)(6)
Rule 12(b)(6) of the Federal Rules of Civil Procedure authorizes the filing of a
motion to dismiss a case for failure to state a claim upon which relief can be granted. FED.
R. Crv. P. 12(b )(6). 	"While a complaint attacked by a Rule 12(b )(6) motion to dismiss
does not need detailed factual allegations, a plaintiff's obligation to provide the grounds of
his entitlement to relief requires more than labels and conclusions, and a formulaic
recitation of a cause of action's elements will not do." Bell At!. Corp. v. Twombly, 127 S.
Ct. 1955, 1965 (2007) (internal quotation omitted). A plaintiff must allege sufficient facts
to state a claim to relief that is "plausible on its face." 	Id. at 1974. A claim is facially
plausible when a "plaintiff pleads factual 	content that allows the court to draw the
reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v.
Iqbal, 129 S. Ct. 1937, 1949 (2009) (citing Twombly, 127 S. Ct. at 1965).
III. 	DISCUSSION
Easton challenges the BOP's failure to transfer her to pre-release custody promptly
when she first became eligible. 	The Fifth Circuit has explained that a challenge to the
BOP's failure to transfer a prisoner to pre-release custody does not affect the duration of
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confinement and, therefore, not cognizable in a habeas corpus action under 28 U.S.C.
§ 2241 but is a civil rights case under Bivens. See Maxwell v. Thomas, 133 F.4th 453-54
(5th Cir. 2025) (explaining the Fifth Circuit's "bright-line rule" that where, as here, a
prisoner's "requested relief is transfer to a halfway house or home confinement," such
relief is properly sought in "a civil rights suit under Bivens") ( citing Melot v. Bergami, 970
F.3d 596, 599 (5th Cir. 2020)).
Easton is represented by counsel, and her pleadings expressly disclaim any Bivens
cause of action. Doc. No. 1 at 3-4 & n.3. Therefore, her original complaint fails to state a
claim for which relief may be granted. 	However, Easton requests leave to amend her
complaint to add a Bivens claim. Doc. No. 13 at 9. Leave to amend should be freely given
"w hen justice so requires." 	FED. R. Crv. P. 	15(a)(2). 	Accordingly, the Court will
conditionally grant the Defendants' motion, and this case will be dismissed after 30 days
unless Easton files an amended complaint that cures the deficiencies in her pleadings.
IV. 	CONCLUSION AND ORDER
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Based on the foregoing, the Court ORDERS as follows:
1. 	The Defendants ' motion to dismiss (Doc. No. 12) is conditionally GRANTED,
insofar as this case will be dismissed thirty (30) days after the entry of this Order,
unless the Plaintiff files an amended complaint curing the deficiencies by that
date.
2. 	Plaintiffs motion to amend (Doc. No. 13 at 9) is GRANTED, and she shall have
thirty (30) days from the entry of this Order to amend her complaint.
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3. 	Plaintiffs pending motions regarding a preliminary injunction (Doc. Nos. 2 &
9) and Defendants' pending motion for a scheduling order (Doc. No. 10) are
DENIED.
The Clerk will send a copy of this Order to all parties of record.
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SIGNED on this __c:,L-	__ day of July 2026.
~LlSANDREW S. HANEN
UNITED STATES DISTRICT JUDGE
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