Chapman v. United States Bureau of Prisons
- Eric Tostrud
- 0:25-cv-03358
- U.S. District Court · District of Minnesota
- 4
In Chapman v. United States Bureau of Prisons, Magistrate Judge Micko recommends denying Mindy L. Chapman's petition seeking $50,000 per day in monetary damages for allegedly being held in federal prison eight days too long, because a petition for a writ of habeas corpus (a legal tool for getting out of detention) cannot be used to seek money damages, and dismissing the case without prejudice so she may refile using the correct legal vehicle.
Federal prisoners or former federal prisoners who believe they were held past their lawful release date and are considering filing a habeas petition to seek monetary damages. This opinion clarifies that habeas petitions cannot be used to obtain money damages and identifies the procedural hurdles — including exhausting administrative remedies and naming the correct defendant — that apply to any future damages claim.
What happened
In Chapman v. United States Bureau of Prisons (Case No. 25-cv-3358), Mindy L. Chapman was released from federal prison on July 24, 2025, but believes she should have been released on July 16, 2025 — eight days earlier. She filed a petition for a writ of habeas corpus seeking $50,000 in monetary damages for each day she was allegedly held beyond her lawful release date. At the time she filed, she had already been released from prison and was on supervised release.
The court explained that a habeas corpus petition — a legal request asking a court to examine whether someone's detention is lawful and, if not, to order their release — is designed only to get someone out of custody sooner, not to win money damages for past wrongful imprisonment. Because Ms. Chapman was already free when she filed, there was no detention to end, and money damages are simply not available through a habeas petition. The court also explored whether the petition could be treated as a different type of lawsuit, but concluded that would be futile: the Bureau of Prisons is not a proper defendant for a constitutional damages claim (which must name the individual responsible) or a Federal Tort Claims Act lawsuit (which must name the United States itself), she likely has not yet formally presented her damages claim to the Bureau of Prisons as required before filing an FTCA suit, and the District of Minnesota may not even be the right court geographically.
Magistrate Judge Micko recommends that the habeas petition be denied and the case dismissed without prejudice — meaning Ms. Chapman is not permanently barred from pursuing her claims, but must bring the correct type of lawsuit, against the correct defendant, in the correct court. Because this is a report and recommendation from a magistrate judge (a judicial officer who assists the district court), Ms. Chapman has 14 days to file written objections with the District Court before the recommendation becomes final.
The detailed version
- Mindy L. Chapman v. United States Bureau of Prisons, No. 25-cv-3358 (ECT/DLM) **Judicial Officer:** Magistrate Judge Douglas L. Micko (issuing a Report and Recommendation, not a final order)
- September 26, 2025
Background
Petitioner Mindy L. Chapman was released from Bureau of Prisons (BOP) custody on July 24, 2025. She contends she should have been released on July 16, 2025, and filed a petition for a writ of habeas corpus seeking $50,000 in monetary damages for each day she was allegedly held beyond her lawful release date. The court reviewed the petition under Rule 4 of the Rules Governing Section 2254 Cases (which allows courts to screen habeas petitions and recommend dismissal before requiring a response), applied here through Rule 1(b) because the petition is not a standard § 2254 petition.
Mootness of Habeas Relief
The court noted that habeas corpus is a remedy for obtaining release from unlawful detention. Ms. Chapman was already free when she filed, so there is no ongoing detention to remedy. The court acknowledged that Ms. Chapman technically remains 'in custody' for habeas purposes because she is on supervised release, but she did not allege that her supervised release term was being extended unlawfully or seek earlier termination of supervised release — and even if she had, venue in Minnesota would likely be improper because her supervised release is not being carried out there. See 28 U.S.C. § 2241(a).
Money Damages Not Available in Habeas
The court stated clearly that monetary damages are not a remedy available through a habeas petition. Citing Kruger v. Erickson, 77 F.3d 1071, 1073 (8th Cir. 1995), and Marcum v. Olmsted County Health, 2024 WL 4480248 (D. Minn. 2024), the court explained that habeas is for getting out of detention sooner, not for compensation.
Why Reconstruing the Petition Would Be Futile
The court considered whether to treat the petition as a different type of civil action under Spencer v. Haynes, 774 F.3d 467, 471 (8th Cir. 2014), but concluded doing so would be futile for multiple independent reasons: - Bivens claim: A Bivens action (a judicially-created remedy allowing damages claims for federal constitutional violations) can only be brought against the individual federal officer(s) responsible, not against a federal agency like the BOP. See F.D.I.C. v. Meyer, 510 U.S. 471, 486 (1994). - Federal Tort Claims Act (FTCA): An FTCA suit must name the United States itself as defendant, not a specific federal agency. See Meyer, 510 U.S. at 476-77. Additionally, under 28 U.S.C. § 2675(a), a claimant must first present the tort claim administratively to the relevant agency and have it denied (or wait six months) before filing in court. The court found it highly unlikely that Ms. Chapman had completed this administrative exhaustion process for her tort claim, since the alleged wrongful detention occurred very recently. - Venue: Under 28 U.S.C. § 1391(e)(1), a plaintiff may sue the United States in the district where she resides, even if the events did not occur there. However, Ms. Chapman does not appear to reside in Minnesota, and she did not allege that any relevant events occurred in Minnesota.
Recommendation
Magistrate Judge Micko recommends: (1) the habeas petition be DENIED; and (2) the action be DISMISSED WITHOUT PREJUDICE, preserving Ms. Chapman's ability to pursue the correct claims, against the correct defendants, in the correct venue and through the correct procedural vehicle.
Next Steps / Objections
Because this is a Report and Recommendation, it is not a final order. Under Local Rule 72.2(b)(1), any party may file written objections within 14 days of being served the report. The report is not directly appealable to the Eighth Circuit Court of Appeals.
Reviewer note from the AI+
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