Woods v. Warden of USP Canaan

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
THERON J. WOODS,
Petitioner
v.
WARDEN OF USP CANAAN,
Respondent.
CIVIL ACTION NO. 3:25-CV-01739
(MEHALCHICK, J.)
MEMORANDUM
Presently pending before the Court is a petition for writ of habeas corpus pursuant to
28 U.S.C. § 2241 filed by Petitioner Theron J. Woods (“Woods”), an inmate currently
confined at the Federal Correctional Institution Buttner Medium II1 (“FCI-Buttner Medium
II”) in North Carolina. (Doc. 1; Doc. 10). Woods asserts that the Bureau of Prisons (“BOP”)
has failed to properly award him prior jailtime credit. (Doc. 1). Because Woods failed to
exhaust his administrative remedies, the Court will dismiss the petition.
1 A § 2241petition 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 relief, but upon the person who holds
him in what is alleged to be unlawful custody.”) While Woods is currently being held at a
facility in North Carolina, at the time the petition was filed, he was housed at USP-Canaan
(Doc. 1) in Wayne County, Pennsylvania, which is located in this district. See 28 U.S.C. §
118(b). The relevant consideration is the district of confinement at the time the petition was
filed. See Barden v. Keohane, 921 F.2d 476, 477 n.1 (3d Cir. 1990). Therefore, this Court is the
proper venue for the action.
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I. 	B ACKGROUND AND P ROCEDURAL HISTORY
In addition to multiple state criminal actions against him, Woods was sentenced to 72
months of imprisonment for possession of a firearm in furtherance of a drug trafficking crime
in the Western District of Virginia2. (Doc. 10, at 4-5). At the time of filing the petition, he had
an projected release date of May 3, 2030, through Good Conduct Time. (Doc. 1, at 3).
Woods filed a letter with the District Court in the Western District of Virgina, which
construed the letter as a petition filed pursuant to 28 U.S.C. § 2241 and transferred it to this
Court. (Doc. 1; Doc. 2). Woods’ letter contends that he his sentence has not been credited for
the three years he has already served. (Doc. 1). He also states that his sentence was to include
the RDAP program, but he was sent to a prison that does not have that program. (Doc. 1).
Woods does not address whether or not he has sought relief through the administrative
process. (Doc. 1).
The Court entered an order serving the letter/petition on Respondent on November
14, 2025. (Doc. 6). Following an extension of time, Respondent filed a response on December
22, 2025. (Doc. 10). Respondent argues that Woods’s letter/petition must be dismissed
because he failed to exhaust his administrative remedies. (Doc. 10). Additionally, Respondent
argues that the petition can be dismissed on its merits. (Doc. 10).
The Court finds that he has failed to exhaust his administrative remedies and will
dismiss the petition.
2 United States v. Woods, No. 4:20-cv-00021-MFU-1, Doc. 84 (W.D. Va. Feb. 22, 2023).
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II. DISCUSSION
Although there is no explicit statutory exhaustion requirement for § 2241 habeas
petitions, the United States Court of Appeals for the Third Circuit has consistently held that
exhaustion applies to such claims. See Callwood v. Enos, 230 F.3d 627, 634 (3d Cir. 2000) (citing
Schandelmeier v. Cunningham, 819 F.2d 52, 53 (3d Cir. 1986)); Moscato v. Fed. Bureau of Prisons,
98 F.3d 757, 760 (3d Cir. 1996). Exhaustion allows the relevant agency to develop a factual
record and apply its expertise, conserves judicial resources, and provides agencies the
opportunity to “correct their own errors” thereby fostering “administrative autonomy.”
Moscato, 98 F.3d at 761-62 (citations omitted). The BOP has a specific internal system through
which federal prisoners can request review of nearly any aspect of their imprisonment. See
generally 28 C.F.R. §§ 542.10-.19. That process begins with an informal request to staff and
progresses to formal review by the Warden, appeal with the Regional Director, and—
ultimately—final 	appeal 	to 	the 	General 	Counsel. 	See 	28 	C.F.R. 	§§ 	542.13-.15. 	No
administrative remedy appeal is considered fully exhausted until reviewed by the General
Counsel. See 28 C.F.R. § 542.15(a).
Exhaustion is the rule in most cases, and failure to exhaust will generally preclude
federal habeas review. See Moscato, 98 F.3d at 761. Only in rare circumstances is exhaustion
of administrative remedies not required. For example, exhaustion is unnecessary if the issue
presented is one that consists purely of statutory construction. See Vasquez v. Strada, 684 F.3d
431, 433-34 (3d Cir. 2012) (citing Bradshaw v. Carlson, 682 F.2d 1050, 1052 (3d Cir. 1981)).
Exhaustion is likewise not required when it would be futile. See Rose v. Lundy, 455 U.S. 509,
516 n.7 (1982). Furthermore, a district court can conclude that an administrative process is
unavailable to a habeas petitioner if “prison administrators thwart inmates from taking
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advantage of a grievance process through machination, misrepresentation, or intimidation.”
Ross v. Blake, 578 U.S. 632, 643–44 (2016).
Woods’s Administrative Remedy Generalized Retrieval report reveals that he has not
filed an administrative remedy request while in BOP custody. (Doc. 10-4). Woods’ offers no
explanation as to why he has not sought an administrative remedy to address his concerns
with either the sentence calculation or the lack of RDAP programming. A case concerning
sentencing calculations, such as this, includes factual assertions for which a record could and
should have been developed prior to filing a habeas petition in this matter. See, e.g., Rosario v.
Spaulding, No. 21-1160, 2021 WL 3884343, at *3 (M.D. Pa. Aug. 31, 2021) (while exhaustion
may be excused for cases solely raising statutory construction issues, this exception does not
apply where a petitioner's request for relief also requires a factual determination as to
completed programming and the amount of credits earned). Therefore, the Court will dismiss
the petition for failure to exhaust his administrative remedies.
III. 	CONCLUSION
For the above stated reasons, the Court will dismiss the petition and close the case. An
appropriate order follows.
Dated: February 2, 2026 	s/ K arolineMehalchick
KAROLINE MEHALCHICK
United States District Judge
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