Narrative Opinion Summary
The appellant sought relief from the district court's denial of his petition under 28 U.S.C. § 2241, arguing that his life sentence had been converted to a fixed term of 540 months by the Bureau of Prisons (BOP) and thereby entitling him to good time credits. He further contended that the BOP should be estopped from denying these credits due to their prior awarding. However, the court found no merit in these claims, reaffirming the absence of evidence supporting a conversion of his sentence to a term of years. The appellant was sentenced to life imprisonment under 21 U.S.C. § 848, rendering him ineligible for good time credits pursuant to 18 U.S.C. § 3624(b), which excludes life sentences from such benefits. Additionally, the appellant's invocation of equitable estoppel was dismissed, as he failed to demonstrate the necessary criteria for its application, with reference to precedent such as Johnson v. Williford. The appellate court affirmed the district court's judgment, emphasizing the non-citable nature of this decision in the circuit, except under specific procedural rules.
Legal Issues Addressed
Eligibility for Good Time Credits under 18 U.S.C. § 3624(b)subscribe to see similar legal issues
Application: The court determined that prisoners serving life sentences are not eligible for good time credits, thus rejecting the appellant's claim.
Reasoning: Consequently, he is not eligible for good time credits, as per 18 U.S.C. § 4161, which was repealed by the Sentencing Reform Act of 1984, and 18 U.S.C. § 3624(b), which states that prisoners serving life sentences are ineligible for such deductions.
Equitable Estoppel in Criminal Sentencingsubscribe to see similar legal issues
Application: The appellant's argument that the Bureau of Prisons is estopped from denying good time credits was denied, as he failed to demonstrate entitlement to equitable estoppel.
Reasoning: Furthermore, Arzola-Amaya failed to demonstrate entitlement to equitable estoppel, referencing Johnson v. Williford for supporting precedent.
Interpretation and Application of Sentencing under 21 U.S.C. § 848subscribe to see similar legal issues
Application: The court confirmed that the appellant was sentenced to life imprisonment under this statute, and no evidence supported the claim of sentence conversion to a fixed term.
Reasoning: The court found these arguments unpersuasive, noting that the record does not support Arzola-Amaya's claim of sentence conversion, as he was sentenced to life imprisonment under 21 U.S.C. § 848.