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Roosa v. Federal Bureau of Prisons

2026-10-20

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

LAUREN ROOSA, et al., )

)

Plaintiffs, )

)

v. ) Civil Action No. 1:26-cv-01919 (UNA)

)

)

)

FEDERAL BUREAU OF PRISONS, et al., )

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Defendants. )

MEMORANDUM OPINION

This matter is before the Court on its initial review of Plaintiffs’ Complaint, ECF No. 1,

and their Applications for Leave to Proceed in forma pauperis (“IFP”), ECF Nos. 5–9. 1 For the

reasons explained below, this matter is dismissed without prejudice.

Plaintiffs Lauren Roosa, Samantha Brown Sanchez, Danielle Phillips, Esther Mbaya,

Teresa Goodroad, Omni Wynne, and Tiffany Wood, are all inmates at FPC Alderson in West

Virginia. Plaintiffs attempt to bring this matter as a class action on behalf of other similarly situated

inmates against the Bureau of Prisons and the BOP’s Director. Plaintiffs contend that the First

Step Act’s (“FSA’s”) “time credit assessment” is, in fact, a “bureaucratic made fiction converting

credits into administrative placeholders” that causes “systematic miscalculation” of an inmate’s

actual release date. They demand that the Court certify the class and appoint them as

representatives, and demand that the Court make substantive changes to the FSA’s application.

1

Plaintiffs’ efforts to proceed IFP also possess fundamental defects. For example, Plaintiff Esther Mbaya has neither submitted an IFP Application nor paid the filing fee; Plaintiff Omni Wynne has filed only a partial and unsigned IFP Application, ECF No. 8, with no accompanying six-month statement, see 28 U.S.C. § 1915(a)(2); Plaintiff Lauren Roosa has filed only a partial and unsigned IFP Application, ECF No. 6, and her attached six month statement is not certified, see 28 U.S.C. § 1915(a)(2).

Plaintiffs may not file a class action, or otherwise bring claims on behalf of other plaintiffs,

because a pro se litigant can represent only herself in federal court. See 28 U.S.C. § 1654 (“In all

courts of the United States the parties may plead and conduct their own cases personally or by

counsel . . . ”); Georgiades v. Martin–Trigona, 729 F.2d 831, 834 (D.C. Cir. 1984) (individual

“not a member of the bar of any court . . . may appear pro se but is not qualified to appear in

[federal] court as counsel for others”) (citation and footnote omitted); see also Moses v. Howard

Univ. Hosp., 606 F.3d 789, 794–95 (D.C. Cir. 2010) (holding that standing exists only to redress

or otherwise to protect against injury to the complaining party and a plaintiff must assert their own

legal rights and interests and cannot rest their claim to relief on the legal rights or interests of third

parties); Singh v. Carter, 185 F. Supp. 3d 11, 21 n. 4 (D.D.C. 2016) (same).

And insofar as the Plaintiffs raise individual claims for alleged calculation errors, such a

claim must be addressed through individual petitions for writ habeas corpus under 28 U.S.C.

§ 2241, see Chatman-Bey v. Thornburgh, 864 F.2d 804, 809–10 (D.C. Cir. 1988) (relying on

Preiser v. Rodriguez, 411 U.S. 475, 489–90 (1973)), making their “immediate custodian” the only

proper respondent in such an action. See Rumsfield v. Padilla, 542 U.S. 426, 434–35 (2004); see

also Blair-Bey v. Quick, 151 F.3d 1036, 1039 (D.C. Cir. 1998) (“[T]he appropriate defendant in a

habeas action is the custodian of the prisoner.”) (citing Chatman-Bey v. Thornburg, 864 F. 2d 804,

810 (D.C. Cir. 1988) (en banc)). To that same end, an action brought under § 2241 must filed in

the district where the petitioner is currently incarcerated. See Stokes v. U.S. Parole Comm'n, 374

F.3d 1235, 1239 (D.C. Cir. 2004) (finding that the district court “may not entertain a habeas

petition involving present physical custody unless the respondent custodian is within its territorial

jurisdiction.”); see also In re Tripati, 836 F.2d 1406, 1407 (D.C. Cir. 1988) (“A habeas petition

may be adjudicated only in the district in which [defendant’s] immediate custodian, his warden, is located.”); Day v. Trump, 860 F.3d 686, 691 (D.C. Cir. 2017) (affirming dismissal for want of

jurisdiction where the District of Columbia was not “the district of residence of [petitioner’s]

immediate custodian for purposes of § 2241 habeas relief”). Consequently, Plaintiffs must pursue

their individual claims, if any, against their current warden in the U.S. District Court for the

Southern District of West Virginia.

For all of these reasons, this case is dismissed without prejudice. Plaintiffs’ IFP

Applications, ECF Nos. 5–9, and Motions for Temporary Restraining Orders, ECF Nos. 2–3,

putatively brought by “all putative class members” are all denied. A separate Order accompanies

this Memorandum Opinion.

TREVOR N. McFADDEN

Date: October 20, 2026 United States District Judge