Eldridge v. Berkebile, No. 15-1053 (10th Cir. 2015)
Annotate this CasePetitioner-appellant Clinton Eldridge appealed the denial of his habeas petition. He pled guilty to various violent felonies and was incarcerated at a federal prison. On appeal, he argued that the Bureau of Prisons (BOP) incorrectly computed his sentence by not crediting all of his time served from his original sentencing hearing through his resentencing, a period of nearly nine years. He also argued that the district court failed to address his arguments concerning credit for time he served from his arrest to his original sentencing (235 days) and for time he served after his parole (for an earlier crime) was revoked (61 days). Because Eldridge was convicted and sentenced in the District of Columbia Superior Court, a court of general jurisdiction separate from the United States District Court for the District of Columbia, the Tenth Circuit concluded it was not obvious whether petitioner was a federal or state prisoner. Under 28 U.S.C. 2253(c)(1), if Eldridge was a state prisoner, he had to obtain a Certificate of Appealability (COA) before he could appeal. If he was a federal prisoner, he did not need a COA to appeal a final judgment in a section 2241 case. The Tenth Circuit concluded that Eldridge was a state prisoner for purposes of section 2253(c)(1) and that he had to obtain a COA to proceed on appeal. The Court further concluded that Eldridge did not meet the necessary showing to obtain a COA. Accordingly, the Court denied a COA and dismissed this appeal.
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