杰克逊诉尼利案

Felicia Yolanda Jackson, a federal prisoner, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241 against Kimberly Neely, challenging her placement at Aliceville FCI rather than Aliceville SPC. The case was filed on July 29, 2024, in the U.S. District Court for the Northern District of Alabama. A magistrate judge issued a report and recommendation on May 7, 2025, recommending denial of the petition. Jackson objected solely on the ground that she "qualifies for preferred housing". On July 18, 2025, District Judge Liles C. Burke overruled the objections, adopted the magistrate judge's recommendation, and dismissed the petition for lack of jurisdiction.

The court dismissed the habeas corpus petition for lack of jurisdiction, holding that challenges to prison housing and security classifications do not challenge the fact or duration of imprisonment and are therefore not cognizable in a § 2241 petition.

Whether a federal prisoner's challenge to her placement in a particular prison facility—as opposed to a preferred housing unit—falls within the scope of habeas corpus relief under 28 U.S.C. § 2241, or whether such a challenge is barred because the Bureau of Prisons' designation of the place of imprisonment is not reviewable by any court under 18 U.S.C. § 3621(b).

The decision reaffirms the longstanding principle that federal courts lack jurisdiction over prisoner challenges to the Bureau of Prisons' housing designations, as such placements are committed to the BOP's unreviewable discretion. The ruling clarifies the boundary between habeas corpus and conditions-of-confinement claims, reinforcing that § 2241 relief is limited to challenges affecting the fact or duration of custody rather than the specific facility or housing unit where a prisoner is confined.