IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF FLORIDA 

TALLAHASSEE DIVISION 

CHRISTOPHER SHORTER 

 a/k/a “Chrissy Shorter” 

 Petitioner, 

v. Case No. 4:20cv223/MW-MAF 

BRYAN DOBBS, WARDEN, 

 Respondent. 

__________________________/ 

GOVERNMENT’S RESPONSE TO THE 

COURT’S MAY 18, 2020, ORDER 

Comes now the United States of America, by and through the undersigned 

Assistant United States Attorney, and files this response to the Court’s May 18, 

2020, order. (ECF 26) For the reasons set forth below, the government argues 

that Defendant, Christopher Shorter, a/k/a “Chrissy Shorter,” is not entitled to 

any relief under the First Step Act and that the petition should be denied. 

STATEMENT OF THE FACTS 

On February 8, 2012, a federal grand jury in the Northern District of 

Florida returned a 55-count Indictment against the defendant, Christopher 

Shorter and co-defendant Kimberly Lewis. (ECF 1; PSR, para. 11

) Count 1 

 

1

 See criminal file, case no. 4:12CR11-001.

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2 

charged the defendants with conspiracy to defraud the government with respect 

to claims between November 14, 2008, and March 27, 2010, in violation of 18 

U.S.C. § 286. (ECF 1, PSR, para. 2) Counts 2 through 26 charged Defendant 

Shorter with defrauding the government with respect to claims, in violation of 

18 U.S.C. § 287. (ECF 1; PSR, para. 3) Counts 27 through 33 charged 

Defendant Shorter and co-defendant Lewis2

 with wire fraud (aiding and 

abetting), in violation of 18 U.S.C. §§ 1843 and 2. (ECF 1; PSR, para. 4) Counts 

d 34 through 51 charged Defendant Shorter with mail fraud (aiding and 

abetting), in violation of 18 U.S.C. §§ 1341 and 2. (ECF 1; PSR, para. 5) Counts 

52 through 55 charged Defendant Shorter with aggravated identity theft (aiding 

and abetting), in violation of 18 U.S.C. §§ 1028A(a)(1) and 2. (ECF 1; PSR, 

para. 6) 

In November 2009, the IRS identified more than 200 income tax returns 

which were believed to be false, due to fraudulent W-2 forms, common 

addresses, and common bank accounts. (PSR, para. 10) These federal tax 

returns were linked to Defendant Shorter and Complete Solutions Tax Services, 

a tax preparation business listing Defendant Shorter and an associate as the 

business owners. (PSR, para. 11) Subsequent investigation revealed more 

fraudulent tax returns, totaling approximately 265 returns for the tax years 2006, 

 

2

 Co-defendant Lewis was also charged in counts 4, 6, 10, 13, 35, 37, 39, 40, and 55. 

Case 4:20-cv-00223-MW-MAF Document 29 Filed 06/11/20 Page 2 of 17
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through 2009. (Id.) The total amount falsely claimed as part of the conspiracy 

was approximately $1,313,520.00. (Id.) Of this amount, Shorter received 

$153,062.00 in successful fraudulent tax return refunds. (Id.) 

On March 29, 2012, Defendant Shorter pled guilty to counts 1, 2 through 

14, 27 through 33, 34 through 44, and 52 through 55. (PSR, para. 8) With an 

offense level of 24 and criminal history category of VI, Defendant Shorter scored 

a guideline imprisonment range of 100 to 125 months on all counts except Count 

1 and 2 through 14. (PSR, paras. 41, 56, 116) On Count 1, the guideline range 

was 100 to 120 months’ imprisonment based on the statutory maximum 

sentence of 120 months. (PSR, para. 116) On Counts 2 through 14, the statutory 

maximum sentence was 60 months’ imprisonment. (Id.) The term of 

imprisonment for Counts 52 through 55 was a consecutive term of 24 months’ 

imprisonment. (Id.) 

On July 31, 2012, Defendant Shorter was sentenced to 72 months’ 

imprisonment on counts 1 and 27 through 44, 60 months’ imprisonment on 

counts 2 through 14, and a consecutive 24 months’ imprisonment on counts 52 

through 55 for a total of 96 months’ imprisonment followed by three years of 

supervised release. (ECF 62) On February 14, 2019, Defendant Shorter 

completed the term of incarceration and began supervised release. (ECF 98) 

After a violation petition was filed, this court modified Defendant Shorter’s term 

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of supervision to clarify that Defendant Shorter “shall not possess or use the 

personal individual information of any individual other than her own.” (ECF 

109). 

On January 8, 2019, Defendant Shorter filed an Emergency Petition for 

relief under 28 U.S.C. § 2241 and an Emergency Motion to Expedite Hearing in 

the Southern District of Florida. (ECF 1, 33

) In the § 2241 petition, Defendant 

Shorter alleged that the “Request for Administrative Remedy is currently 

pending” with the BOP. (ECF 1, p. 4) Defendant Shorter attached documents 

to the petition showing communication with prison personnel. (ECF 1, 

Attachment A, pp. 13-17) On December 26, 2018, Defendant Shorter submitted 

a form entitled “Informal Resolution,” requesting that “56 additional days Good 

time credit” be applied to Defendant Shorter’s sentence under the First Step Act, 

resulting in a release date of December 20, 2018. (Id., p. 13) The correctional 

counselor responded on the bottom of the form: “Your time is not computed at 

the institutional level. Due to the [government] shutdown your immediate 

release may be delayed by the Designation and Sentence Computation Center.” 

(Id.) A unit manager later added: “Although the law may have been signed, 

there has been no guidance issued to the BOP or FCI Miami on how this law 

will effect inmates and any procedures needed. Please be patient while 

 

3

 Citation to the instant case, case no. 4:20cv223/MW-MAF. 

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information is compiled and then executed.” (Id.) On December 27, 2018, 

Defendant Shorter filed a “Request for Administrative Remedy,” which stated 

a desire to “grieve the attached INFORMAL RESOLUTION REQUEST.” 

(Id., p. 16) On January 2, 2019, the Warden responded to Defendant Shorter’s 

email demanding immediate release with an email explaining, “We do not have 

authority to recalculate sentences at the local institution level. We are awaiting 

guidance on how to proceed.” (Id., p. 17). 

The district court referred the petition to a magistrate judge, who, without 

requiring a response from the Warden, issued a Report and Recommendation 

(hereinafter, “R&R”) that Defendant Shorter’s petition be dismissed without 

prejudice due to prematurity and a failure to exhaust administrative remedies. 

(ECF 5) According to the R&R, Defendant Shorter “likely could not qualify for 

any time credits when this Petition was filed... [S]uch time credits do not apply 

before the Act’s date of enactment, and Shorter filed her §2241 petition less than 

30 days after the First Step Act’s enactment.” (Id., p. 5) 

Defendant Shorter objected to the R&R, claiming that “the futility 

exception” excused any requirement to exhaust administrative remedies. (ECF 

8) The district court in the Southern District of Florida dismissed the petition 

on February 15, 2019. (ECF 10) Defendant Shorter timely filed a notice of 

appeal. (ECF 13) Although there was an initial dismissal for lack of 

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prosecution, the Eleventh Circuit Court of Appeals issued mandate on April 13, 

2020, vacating and remanding the petition for further proceedings. (ECF 22) 

The case was transferred to the Northern District of Florida on April 30, 2020. 

(ECF 24) On May 18, 2020, this court issued an order directing the government 

to respond by June 15, 2020. (ECF 26) 

The government responds and opposes the petition as follows: 

LAW AND ARGUMENT 

I. Defendant Shorter is ineligible for relief under the First Step Act. 

This court is authorized to issue a writ of habeas corpus on behalf of a 

prisoner who is “in custody in violation of the Constitution or laws or treaties of 

the United States.” 28 U.S.C. § 2241(c)(3). A petition filed pursuant to 28 

U.S.C. § 2241 petition is appropriate where, a prisoner challenges the execution 

of his federal sentence. Antonelli v. Warden, U.S. P. Atlanta, 542 F.3d 1348, 1352 

(11th Cir. 2008). In the instant case, Defendant Shorter was still “in custody” at 

the time of the filing of the § 2241 petition and is currently serving a term of 

supervised release. (ECF 1; ECF 98 – case no. 4:12CR11-001) Defendant 

Shorter continues to seek good-time credit, even though the sentence of 

imprisonment had been completed. 

The Bureau of Prisons, (hereinafter, “BOP”) uses the provisions in 18 

USC § 3624(b) to determine good conduct time credit on a federal sentence. 

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Section 102(b)(1)(A) of the First Step Act of 2018 amended 18 U.S.C. § 

3624(b)(1) to increase the maximum allowable good-time credit from 47 to 54 

days for each year of the sentence imposed. First Step Act, Pub. L. No. 115-391, 

§ 102(b)(1)(A), 132 Stat. 5194 (2018). Title 18 U.S.C. § 3624(b)(1) now states: 

Subject to paragraph (2), a prisoner who is serving a term of 

imprisonment of more than 1 year other than a term of 

imprisonment for the duration of the prisoner’s life, may receive 

credit toward the service of the prisoner’s sentence, of up to 54 days 

for each year of the prisoner’s sentence imposed by the court, subject 

to determination by the Bureau of Prisons that, during the year, the 

prisoner has displayed exemplary compliance with institutional 

disciplinary regulations. 

18 U.S.C. § 3624(b)(1). 

This provision applies retroactively “to offenses committed before, on, or 

after the date of enactment of this Act, except that such amendments shall not 

apply with respect to offenses of this Act, except that such amendments shall not 

apply with respect to offenses committed before November 1, 1987.” First Step 

Act, Pub. L. No. 115-391, § 102(b), 132 Stat. 5213 (2018). The provisions in the 

First Step Act, however, included a delayed effective date to allow the Attorney 

General time to establish the “risk and needs assessment system” by July 19, 

2019. See Bottinelli v. Salazar, 929 F.3d 1196, 1199 (9th Cir. 2019)(“Congress 

provided ‘clear direction’ in paragraph 102(b)(2) to delay the implementation of 

the good time credit amendment until the Attorney General establishes the ‘risk 

and needs assessment system.’ Like the district court, we refuse to overlook the 

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[First Step] Act's plain text and therefore affirm the denial of the joint habeas 

petition.”) (internal citation omitted). Other district courts have similarly found: 

In accordance with Section 102(b)(2) of the Act, the amendments made in 

this section only take effect when the Attorney General completes the ‘risk 

and needs assessment system’ required by Section 101(a) of the Act. 

Section 101(a) does not require completion of the system until 210 days 

after the Act's enactment. Thus, Section 102(b)(1) will not take effect until 

approximately July 2019. 

Thorpe v. Edge, 2019 U.S. Dist. LEXIS 123579, *3 (S.D. Ga. Jul. 8, 2019), 

(collecting cases), quoting Gilliam v. U. S. Justice Dep’t, No. 219-CV-00037, 2019 

U.S. Dist. LEXIS 78503, 2019 WL 2062544, at *2 (E.D. Ark. Apr. 19, 2019), 

Report and Recommendation adopted sub nom. Gilliam v. Hendrix, 2019 U.S. 

Dist. LEXIS 78103, 2019 WL 2062494 (E.D. Ark. May 9, 2019) (quoting Rizzolo 

v. Puentes, No. 1:19-cv-00290, 2019 U.S. Dist. LEXIS 42957, 2019 WL 1229772 

(E.D. Cal. March 15, 2019)); see also Crittendon v. White, No. 1:19-cv-669, 2019 

U.S. Dist. LEXIS 71568, 2019 WL 1896501 (M.D. Pa. Apr. 29, 2019) (same). 

The Attorney General’s deadline for the risk and needs assessment was July 19, 

2019. 18 U.S.C. § 3632(a). 

To grant Defendant Shorter’s petition, the court would be disregarding the 

plain language of Subsection 102(b)(2), which provides that the amendments 

made in subsection 102(b) of the Act take effect only when the Attorney General 

completes the “risk and needs assessment system” required by Section 101(a) of 

the Act. Wright v. United States, 2019 U.S. Dist. LEXIS 111793, * 13 (W.D. WA. 

Case 4:20-cv-00223-MW-MAF Document 29 Filed 06/11/20 Page 8 of 17
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June 5, 2019). It is undisputed that Congress can postpone the date on which a 

law, or even part of a law, becomes effective. Id., citing Gozlon-Peretz v. United 

States, 498 U.S. 395, 504, 405-08 (1991). And where Congress has provided an 

express effective date for a statutory provision, that date controls. Id, citing 

Gozlon-Peretz, 498 U.S. at 403-404. 

Defendant Shorter was ineligible for relief at the time of filing the petition 

and remains ineligible; and therefore, the petition should be dismissed. See 

Thorpe v. Edge, 2019 U.S. Dist. LEXIS 123579, * 3, citing Wykoff v. Woods, Civil 

Action No.: 2:19-CV-72, 2019 U.S. Dist. LEXIS 82121, 2019 WL 2375257, at 

*2 (M.D. Ala. May 14, 2019) (request for immediate recalculation of sentence 

under § 102(b)(1) premature and subject to dismissal) (collecting cases), Report 

and Recommendation adopted, 2019 U.S. Dist. LEXIS 92823, 2019 WL 

2375176 (June 4, 2019); See also Schmutzler v. Quintana, No. 5:19-046-DCR, 

2019 U.S. Dist. LEXIS 26433, 2019 WL 727794, at *2 (E.D. Ky. Feb. 20, 2019) 

(summarily dismissing § 2241 petition based on delayed effective date of the 

First Step Act as premature and because petitioner failed to exhaust 

administrative remedies); Wright v. United States, 2019 U.S. Dist. LEXIS 

111793, *9-11, n.5, 6 (W.D. WA. June 5, 2019)(collecting cases); Christopher v. 

Wilson, No. 4:19-cv-214-O, 2019 U.S. Dist. LEXIS 66020, 2019 WL 1745968, 

at *1 (N.D. Tex. Apr. 18, 2019); see also Brown v. Warden of FCI Williamsburg, 

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No. 8:19-cv-00546-HMH-JDA, 2019 U.S. Dist. LEXIS 69440, 2019 WL 

1780747, at *6-7 (D.S.C. Mar. 25, 2019); Rizzolo v. Puentes, No. 1:19-cv-00290- 

[*4] SKO-HC, 2019 U.S. Dist. LEXIS 42957, 2019 WL 1229772, at *3 (E.D. 

Cal. Mar. 15, 2019) (same); Sheppard v. Quintana, No. 5:19-cv-084-DCR, 2019 

U.S. Dist. LEXIS 37297, 2019 WL 1103391, at *2 (E.D. Ky. Mar. 8, 2019) 

(same); Sennett v. Quintana, No. 5:19-cv-085-JMH, 2019 U.S. Dist. LEXIS 

36784, 2019 WL 1085173, at *2 (E.D. Ky. Mar. 7, 2019) (same). Accordingly, 

Defendant Shorter’s argument for entitlement to immediate relief lacks merit. 

Defendant Shorter satisfied the prison sentence imposed in Case Number 

4:12cr11-001, on February 14, 2019, and began a three-year term of supervised 

release. Defendant Shorter argues for relief under the First Step Act, even 

though Defendant Shorter is already now released from imprisonment and is 

serving a term of supervised release. Courts considering similar arguments 

under the First Step Act have rejected them as contrary to federal law. See 

Jamison v. Warden, Elkton Federal Correctional Institution, 2019 WL 5690710, *3 

(S.D. OH. Nov. 4, 2019) (“Because petitioner’s revocation sentence is separate 

from his original sentence for purposes of calculating good-time credits, he is not 

entitled to the good-time credits he would have received on his original 36-

month sentence if the First Step Act had been enacted at the time he was serving 

that sentence.”); See also Garland v. Johnson, No. 1:19-cv-53-P, 2019 WL 

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5106274, at *1 (W.D. La. Aug. 12, 2019) (“However, even if [petitioner] had 

been entitled to additional good time credit toward his sentence that he did not 

receive, federal law provides that those credits could not be used either to shorten 

the period of his supervised release or to shorten the period of any future 

imprisonment [petitioner] may be required to serve for violating the conditions 

of his release.”) (citing 28 C.F.R. § 2.35(b) (“Once an offender is conditionally 

released from imprisonment, either by parole or mandatory release, the good 

time earned during that period of imprisonment is of no further effect either to 

shorten the period of supervision or to shorten the period of imprisonment which 

the offender may be required to serve for violation of parole or mandatory 

release.”); United States v. Johnson, 529 U.S. 53, 60 (2000) (holding that the length 

of a term of supervised release may not be reduced by reason of excess time 

incarcerated, as [t]he objectives of supervised release would be unfulfilled if 

excess prison time were to offset and reduce terms of supervised release.”). 

Unlike in Dawson v. Scott, 50 F.3d 884, 886 n. 2 (11th Cir. 1999), the relief 

sought here, good time-credit, could not alter Defendant Shorter’s supervised 

release. See United States v. Sewell, 712 Fed. Appx. 917, 919 (11th Cir. 

2017)(Unlike the petitioners in Dawson and in United States v. Page4

, 69 F.3d 482, 

 

4

 Superseded by statute on unrelated ground as stated in United States v. Edwards, 728 F.3d 1286, 1292 (11th

Cir. 2013). 

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487 n.4 (11th Cir. 1995), if the petitioner prevailed, his supervised release term 

would not change. “Nothing in the record suggests that if the District Court had 

imposed a shorter sentence, it would also have imposed a shorter or less 

restrictive period of supervised release.”) In the instant case, on Counts 1, 2 

through 14, 27 through 33, and 34 through 44, the district court was authorized 

to impose a term of supervised release of not more than three years pursuant to 

18 U.S.C. §3583(b)(2). (PSR, para. 118) For those same counts of conviction, 

the Sentencing Guidelines provided that the authorized term of supervised 

release was at least one year, but not more than three years, pursuant to USSG 

§5D1.2(a)(2). (PSR, para. 119) Hence, as the Eleventh Circuit held in Sewell, 

even if Defendant Shorter were to prevail on the petition, nothing in the record 

suggests that Defendant Shorter’s success would have any effect on the threeyear term of supervised release currently being served.

Moreover, there is absolutely nothing in the First Step Act which 

mandates the BOP to retroactively un-satisfy and update previously satisfied 

sentences, thereby causing every previously served sentence which was granted 

good conduct time credits under Title 18, USC § 3624(b) to become overserved. 

As such, Defendant Shorter cannot receive additional good conduct time credit 

towards a previously served term of imprisonment under the updated statute 

prior to the statute’s effective date of July 19, 2019. Defendant Shorter’s claims 

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alleging that the failure to apply good-time credit under the First Step Act 

violated the defendant’s 4th and 8th amendment rights are meritless. Accordingly, 

Defendant Shorter’s petition should be denied in its entirety. 

II. Defendant Shorter failed to exhaust the administrative remedies. 

Even if Defendant Shorter had not completed the term of supervision at 

the time of enactment of the good time provision under the First Step Act, 

Defendant Shorter’s petition would be subject to dismissal for failing to exhaust 

administrative remedies. Defendant Shorter initiated the administrative process, 

but there was admittedly no exhaustion5

. (ECF 1, p. 9; ECF 8, p. 2) Although 

§ 2241 does not contain a statutory exhaustion requirement, courts consistently 

require the exhaustion of administrative remedies prior to review. Santiago-Lugo 

v. Warden, 785 F.3d 467 (11th Cir. 2015); See also Davis v. Warden, FCC ColemanUSP, 661 F. Appx. 561, 562 (11th Cir. 2016) (federal inmate seeking habeas 

corpus relief under § 2241 “must exhaust available administrative remedies 

before he can obtain relief”) (citing Santiago-Lugo, 785 F.3d at 474-75)). This 

common practice in the courts is important, because “[e]xhaustion allows prison 

officials to develop a factual record and an opportunity to correct their own 

errors before being haled into court.” Brimmer v. Warden of FCI-Williamsburg, 

 

5

 “Petitioner [Defendant Shorter] alleges, while assuming he would fail at the initial stage of 

administrative complaints, that it would take too much time to go through the 

administrative process.” (ECF 8, p. 2) 

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No. CV 9:19-676, 2019 U.S. Dist. LEXIS 91579, 2019 WL 2305022, at *3 

(D.S.C. Apr. 30, 2019), Report and Recommendation adopted, 2019 U.S. Dist. 

LEXIS 90307, 2019 WL 2303585 (D.S.C. May 30, 2019) (citing Jones v. Bock, 

549 U.S. 199, 204, 127 S. Ct. 910, 166 L. Ed. 2d 798 (2007)). 

The BOP has established an administrative remedy procedure through 

which an inmate may seek review of a grievance related to the inmate’s 

imprisonment. 28 C.F.R. § 542.10 et seq. This process “applies to all inmates 

in institutions operated by the Bureau of Prisons . . . and to former inmates for 

issues that arose during their confinement.” 28 C.F.R. § 542.10(b). An inmate 

must generally first seek to resolve an issue of concern informally by presenting 

the issue to correctional staff. 28 C.F.R. § 542.13(a). If no resolution 

materializes, the inmate must submit a formal written request to the Warden 

within 20 calendar days. 28 C.F.R. § 542.14(a). If unsatisfied with the Warden's 

response, the inmate may then appeal with the BOP Regional Director within 

20 days of the Warden's response. 28 C.F.R. § 542.15(a). If still dissatisfied with 

the BOP Regional Director's response, the inmate may finally appeal to the 

BOP's Office of General Counsel in Washington, D.C., within 30 days of the 

BOP Regional Director’s signature on the response. Id. Inmates must complete 

all three steps of the administrative remedies process to have exhausted their 

administrative remedies. 

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Defendant Shorter argues that the futility exception applies here. (ECF 8) 

In 28 U.S.C.S. § 2241 cases, this exception applies only in “extraordinary 

circumstances,” for which Defendant Shorter fails to meet the burden of 

demonstrating the futility of administrative review. Tinoco-Jaimes v. United 

States, 168 Fed. Appx. 356, 359 (11th Cir. 2006)(Petitioner failed to demonstrate 

extraordinary circumstances and did not adequately explain why the 

administrative process would have been futile.). The question becomes whether 

Defendant Shorter has established that extraordinary circumstances existed 

when Defendant Shorter chose not to complete the administrative process and 

instead, filed his petition in district court. (ECF 1) 

There was nothing preventing Defendant Shorter from timely appealing 

the Warden’s response within 20 days to the BOP Regional Director. Defendant 

Shorter could have and should have immediately appealed to the BOP Regional 

Director as early as January 2, 20196

, the Warden’s decision date. (ECF 1, 

Attachment A, p. 17) Then, from that point, if Defendant Shorter would have 

remained displeased with the BOP Regional Director’s decision, Defendant 

Shorter should have appealed to the BOP’s Office of General Counsel. Instead, 

Defendant Shorter decided to file the petition in district court. Defendant 

 

6

 Defendant Shorter was released from incarceration and started supervised release on 

February 14, 2019 (almost six weeks after the Warden’s decision). (ECF 98)

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Shorter has failed to establish that the administrative process would have been 

futile. 

Accordingly, Defendant Shorter’s 2241 petition should be denied for 

failure to exhaust administrative remedies. 

 Respectfully submitted, 

LAWRENCE KEEFE

 United States Attorney 

 

s/Winifred L. Acosta 

 WINIFRED L. ACOSTA 

 Assistant U.S. Attorney 

Appellate Division 

 Northern District of Florida 

 Florida Bar No. 0076333 

 111 North Adams Street, 4th Floor 

 Tallahassee, FL 32301 

 (850) 942-8430 

 winifred.acosta@usdoj.gov 

CERTIFICATE OF COMPLIANCE WITH N.D. FLA. LOC. R. 7.1(F) 

I hereby certify that this response complies with the word limitation set 

forth in N.D. Fla. Loc. R. 7.1(F). This response contains 3,516 words. 

 s/ Winifred L. Acosta 

 Winifred L. Acosta 

 Assistant U.S. Attorney 

Case 4:20-cv-00223-MW-MAF Document 29 Filed 06/11/20 Page 16 of 17
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CERTIFICATE OF SERVICE 

I hereby certify that a copy of the fore-going has been provided by U.S. 

mail to Christopher Shorter, a/k/a “Chrissy Shorter,” 121 James Court, 

Quincy, FL 32351 on this 11th day of June, 2020. 

 s/ Winifred L. Acosta 

 Winifred L. Acosta 

 Assistant U.S. Attorney 

Case 4:20-cv-00223-MW-MAF Document 29 Filed 06/11/20 Page 17 of 17