Jeffrey Jones v. B. Lammer
CourtCourt of Appeals for the Seventh Circuit
Date FiledJuly 29, 2026
Docket25-2921
StatusPublished
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Full Opinion
In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 25-2921
JEFFREY R. JONES,
Petitioner-Appellant,
v.
BRIAN LAMMER,
Respondent-Appellee.
____________________
Appeal from the United States District Court for the
Western District of Wisconsin.
No. 25-cv-661-jdp — James D. Peterson, Chief Judge.
____________________
SUBMITTED JULY 28, 2026 * — DECIDED JULY 29, 2026
____________________
Before SCUDDER, ST. EVE, and MALDONADO, Circuit Judges.
PER CURIAM. Jeffrey Jones, a federal prisoner convicted of
drug trafficking offenses, challenges the dismissal of his peti-
tion for relief for under 28 U.S.C. § 2241. He contests the de-
* We have agreed to decide the case without oral argument because
the briefs and record adequately present the facts and legal arguments,
and oral argument would not significantly aid the court. FED. R. APP. P.
34(a)(2)(C).
2 No. 25-2921
termination of the Federal Bureau of Prisons that his convic-
tion for distributing fentanyl makes him ineligible for that re-
lief. We affirm.
Jones pleaded guilty in 2021 to distributing 40 grams or
more of a mixture or substance containing fentanyl,
see 21 U.S.C. § 841(a), (b)(1)(B)(vi); 18 U.S.C. § 2, and was sen-
tenced to 150 months’ imprisonment. In 2025, he petitioned
under 28 U.S.C. § 2241 for a writ of habeas corpus, arguing
that the Bureau of Prisons arbitrarily denied him time credits
under the First Step Act. He argued that two of the Act’s stat-
utory provisions—18 U.S.C. § 3632(d)(4)(D)(lxvi) and (lxviii),
which exclude prisoners with certain drug convictions from
earning time credits—conflict and that their application is am-
biguous.
The district court denied the petition. The court deter-
mined that Jones’s conviction under § 841(b)(1)(B)(vi) for dis-
tributing 40 grams or more of a mixture or substance contain-
ing fentanyl rendered him ineligible under
§ 3632(d)(4)(D)(lxvi) for time credits under the Act. And the
court concluded that Jones failed to show any inconsistency
or redundancy between § 3632(d)(4)(D)(lxvi) and
§ 3632(d)(4)(D)(lxviii).
We begin with a few words about the First Step Act. The
Act provides eligible federal prisoners with the opportunity
to earn time credits by “successfully complet[ing] evidence-
based recidivism reduction programming or productive ac-
tivities.” 18 U.S.C. § 3632(d)(4)(A). But certain enumerated
convictions disqualify prisoners from earning time credits.
See id. § 3632(d)(4)(D). Relevant here, the Act expressly ex-
cludes prisoners convicted under 21 U.S.C. § 841(b)(1)(B)(vi)
No. 25-2921 3
for distributing 40 grams or more of a mixture or substance
containing fentanyl from being eligible for time credits:
Ineligible prisoners.--A prisoner is ineligi-
ble to receive time credits under this paragraph
if the prisoner is serving a sentence for a convic-
tion under any of the following provisions of
law: ….
(lxvi) Subparagraph (A)(vi) or (B)(vi) of sec-
tion 401(b)(1) of the Controlled Substances Act
(21 U.S.C. 841(b)(1)) or paragraph (1)(F) or (2)(F)
of section 1010(b) of the Controlled Substances
Import and Export Act (21 U.S.C. 960(b)), relat-
ing to manufacturing, distributing, dispensing,
or possessing with intent to manufacture, dis-
tribute, or dispense, a mixture or substance con-
taining a detectable amount of N-phenyl-N-[1-
(2-phenylethyl)-4-piperidinyl] propanamide, or
any analogue thereof. †
18 U.S.C. § 3632(d)(4)(D)(lxvi). Similarly, a prisoner is dis-
qualified from earning time credits if (a) he is convicted under
§ 841(b)(1), and (b) the sentencing court finds that “the offense
involved a mixture or substance containing a detectable
amount of” fentanyl and the prisoner “was an organizer,
leader, manager, or supervisor of others in the offense.”
Id. § 3632(d)(4)(D)(lxviii).
On appeal, Jones concedes that his conviction falls under
§ 3632(d)(4)(D)(lxvi) but maintains that this provision is in
† N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide is a sci-
entific term for fentanyl.
4 No. 25-2921
“irreconcilable conflict” with § 3632(d)(4)(D)(lxviii). Both pro-
visions overlap, he says, in that they address fentanyl-related
convictions, but he urges he should be eligible for time credits
because the sentencing court did not find that he was a leader
or supervisor for purposes of § 3632(d)(4)(D)(lxviii). And be-
cause the application of these provisions is ambiguous, he ar-
gues that the ambiguity should be resolved in his favor.
As the district court rightly concluded, there is no ambi-
guity concerning the application of § 3632(d)(4)(D)(lxvi) and
§ 3632(d)(4)(D)(lxviii). The provisions deny time-credit eligi-
bility for different courses of conduct: § 3632(d)(4)(D)(lxvi)
applies when a prisoner’s offense involves a threshold quan-
tity of mixtures or substances including fentanyl, while
§ 3632(d)(4)(D)(lxviii) applies when the offense involves a de-
tectable amount of fentanyl and the prisoner acted as a leader
or supervisor in the offense. That a prisoner could conceiva-
bly be rendered ineligible for time credits under both provi-
sions does not mean that a prisoner is eligible for time credits
when his offense falls under one provision but not the other.
AFFIRMED