Watkins v. Warden

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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
DEMOS WATKINS,
Petitioner,
v.
WARDEN, FCI LEWISBURG,
Respondent.
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Civil No. 1:26-CV-00449
Judge Jennifer P. Wilson
MEMORANDUM
Before the court is a petition for writ of habeas corpus filed by Demos
Watkins (“Petitioner”), an inmate currently housed at the Federal Correctional
Institution Lewisburg (“FCI-Lewisburg”). (Doc. 1.) Specifically, Petitioner
alleges that the Bureau of Prisons (“BOP”) should apply his earned time credits
under the First Step Act (“FSA”) in excess of 365 days towards placement in home
confinement. (Id.) The court considered a petition making an identical argument
filed by Petitioner in January of 2026 and concluded that Petitioner’s claims under
the FSA are not cognizable under Section 2241. Watkins v. Warden of FCI-
Lewisburg, No. 1:26-CV-00138 (M.D. Pa. Jan. 26, 2026). Therefore, the court will
dismiss the petition.
BACKGROUND AND PROCEDURAL H ISTORY
Petitioner initiated an action in this court by filing a petition for writ of
habeas corpus pursuant to 28 U.S.C. § 2241that the court received and docketed on
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January 21, 2026. Watkins, No. 1:26-CV-00138, Doc. 1. Petitioner provided
documentation that he was granted the full 365 days of early release from earned
time credits under the FSA. Id., Doc. 1-1. It appeared that he had earned time
credits in excess of the 365 days, totaling 1981 days with 595 days available to
apply to towards prerelease placement such has a residential reentry center
(“RRC”) or home confinement. Id. Plaintiff filed the petition seeking application
of these 595 days of excess credit under the FSA. Id., Doc. 1. The court screened
the petition pursuant to Rule 4 and determined that petitioner’s habeas challenge
was not cognizable and dismissed the petition. Id., Doc. 4.
On February 24, 2026, the court received and docketed Petitioner’s current
petition seeking an order of the court instructing the Warden at FCI-Lewisburg to
recalculation his prerelease eligibility date applying all accrued credits earned
under the FSA and effectuate transfer into a prerelease custody. (Doc. 1.) The
instant petition makes arguments identical to those raised in the January petition.
(Id.) Petitioner paid the requisite filing fee, and the court will now screen the
petition consistent with Rule 4.
VENUE
A § 2241 petition must be filed in the district where the petitioner is in
custody. See Braden v. 30th Judicial Circuit Court of Kentucky, 410 U.S. 484,
494–95 (1973) (“The writ of habeas corpus does not act upon the person who seeks
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relief, but upon the person who holds him in what is alleged to be unlawful
custody.”) Petitioner is being held at FCI-Lewisburg in Union County,
Pennsylvania, which is in this district. See 28 U.S.C. § 118(b). Therefore, this
court is the proper venue for the action.
STANDARD
This matter is before the court for screening pursuant to 28 U.S.C. § 2243.
The § 2241 petition has been given preliminary consideration pursuant to Rule 4 of
the Rules Governing Section 2254 Cases in the United States District Courts, 28
U.S.C. § 2254 (applicable to § 2241 petitions under Rule 1(b)). Rule 4 may be
applied at the discretion of the district court as it is the duty of the court to screen
out frivolous applications and eliminate the burden that would be placed on the
respondent by ordering an unnecessary answer. Allen v. Perini, 424 F.2d 134, 141
(6th Cir. 1970).
DISCUSSION
Here, Petitioner is attempting to relitigate an identical claim previously
resolved by this court. He brings the same claim and seeks the same relief as in the
January 2026 petition. It is well established that principles of res judicata apply to
habeas petitions and forbid the re-litigation of claims previously settled between
the parties in prior litigation. See Anselmo v. Hardin, 253 F.2d 165 (3d Cir. 1958).
Therefore, the court will dismiss the petition.
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CONCLUSION
For the above stated reasons, the court will dismiss the petition and close the
case. An appropriate order follows.
s/Jennifer P. Wilson
JENNIFER P. WILSON
United States District Judge
Middle District of Pennsylvania
Dated: March 9, 2026
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