Eric Bartoli v. Director Federal Bureau of Prisons
Court
Third Circuit Court of Appeals
Decided
June 10, 2025
Jurisdiction
F
Importance
48%
Practice Areas
Case Summary
DLD-156 NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________ Nos. 25-1426 & 25-1427 ___________ ERIC BARTOLI, Appellant v. DIRECTOR FEDERAL BUREAU OF PRISONS; WARDEN LORETTO FCI ___________ ERIC BARTOLI, Appellant v. WARDEN LORETTO FCI ____________________________________ On Appeals from the United States District Court for the Western District of Pennsylvania (D.C. Civil Action Nos. 3:23-cv-00204 & 3:23-cv-00057) Magistrate Judge: Honorable Patricia L. Dodge ____________________________________ Submitted for Possible Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6 May 22, 2025 Before: RESTREPO, FREEMAN, and NYGAARD, Circuit Judges (Opinion filed: June 10, 2025) _________ OPINION * * This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not _________ PER CURIAM Pro se Appellant Eric Bartoli appeals from District Court orders dismissing his two petitions for writ of habeas corpus that he filed pursuant to 28 U.S.C. § 2241. We will affirm. I Bartoli fled to Peru after a grand jury indicted him for crimes related to his running a Ponzi scheme. Years later, he was arrested and extradited to face those charges in the United States District Court for the Northern District of Ohio. He pled guilty in that Court to charges related to that Ponzi scheme. Bartoli received a sentence of 20 years’ imprisonment and was ordered to pay $42 million in restitution. Bartoli’s direct appeal proved unsuccessful. See United States v. Bartoli, 728 F. App’x 424 (6th Cir. 2018), cert. denied, Bartoli v. United States, 587 U.S. 925 (2019). Bartoli then sought collateral relief by filing a motion pursuant to 28 U.S.C § 2255 See United States v. Bartoli, C.A. No. 23-3983, 2024 WL 4987352, at *1-2 (6th Cir. Dec. 5, 2024) (discussing Bartoli’s collateral proceedings). While Bartoli’s § 2255 proceedings were pending, he filed two § 2241 habeas corpus petitions in the Western District of Pennsylvania (where he was incarcerated) in April 2023 and September 2023. In his April 2023 petition, Bartoli argued that his extradition to the United States from Peru constitute binding precedent. 2 prior to his conviction was illegal and violated the Ex Post Facto Clause, and that trial counsel’s failure to raise this issue constituted ineffective assistance. In his September 2023 petition, Bartoli challenged the validity of his sentence pursuant to the Double Jeopardy and Due Process Clauses as well as the Eighth Amendment. On February 25, 2025, the District Court 1 dismissed both petitions for lack of jurisdiction. Bartoli appealed. This Court notified the parties that these appeals, which have since been consolidated, might be subject to summary action. Appellees filed responses to that notification. Bartoli did not. II We have jurisdiction under 28 U.S.C. § 1291. In reviewing the District Court’s dismissals of Bartoli’s § 2241 habeas corpus petitions, we exercise plenary review over its legal conclusions and review findings of fact for clear error. See O’Donald v. Johns, 402 F.3d 172, 173 n.1 (3d Cir. 2005) (per curiam). We may summarily affirm the District Court’s decisions if the appeals fail to present a substantial question. See 3d Cir. L.A.R. 27.4; 3d Cir. I.O.P. 10.6; see also Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011) (per curiam). III Section 2241 gives a District Court jurisdiction over “the petition of a federal prisoner who is [attacking] not the validity but the execution of his sentence.” Cardona v. 1 The parties consented to Magistrate Judge jurisdiction pursuant to 28 U.S.C. § 636(c)(1) in both cases. 3 Bledsoe, 681 F.3d 533, 535 (3d Cir. 2012). Here, however, Bartoli challeng
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Status
Decided
Date Decided
June 10, 2025
Jurisdiction
F
Court Type
appellate
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Case Summary
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Case Overview
Case Name: Eric Bartoli v. Director Federal Bureau of Prisons
Court: Court of Appeals for the Third Circuit
Date: June 10, 2025
Citation: Unknown
In this case, pro se appellant Eric Bartoli appealed the dismissal of his two petitions for writ of habeas corpus under 28 U.S.C. § 2241 by the District Court for the Western District of Pennsylvania. The appeals were consolidated and reviewed by the Third Circuit.
Key Legal Issues
- Jurisdictional Authority: Whether the District Court had jurisdiction to entertain Bartoli's habeas corpus petitions.
- Nature of Claims: Bartoli's claims were centered on his underlying criminal conviction and sentence rather than the execution of his sentence.
- Ineffectiveness of § 2255: Whether the remedy under 28 U.S.C. § 2255 was inadequate or ineffective for Bartoli to challenge his detention.
Court's Decision
The Third Circuit affirmed the District Court's dismissal of Bartoli's petitions for lack of jurisdiction. The court concluded that Bartoli's claims did not fall under the purview of § 2241, as they pertained to the validity of his conviction rather than the execution of his sentence.
Legal Reasoning
The Court emphasized that § 2241 is designed for federal prisoners to challenge the execution of their sentences, not the validity of their convictions. The court stated:
- Motions under § 2255 are the standard means for federal prisoners to contest their convictions or sentences.
- A § 2241 petition can only be entertained if the remedy under § 2255 is shown to be inadequate or ineffective, which was not the case for Bartoli.
- The court referenced the precedent set in Jones v. Hendrix, highlighting that the inability to meet the conditions for filing a § 2255 motion does not permit a prisoner to seek relief under § 2241.
Key Holdings
- The Third Circuit confirmed that Bartoli's petitions were improperly filed under § 2241.
- The court reiterated that the District Court correctly dismissed Bartoli's petitions due to a lack of jurisdiction.
- The court's ruling underscores the importance of following the correct procedural avenues for challenging federal convictions.
Precedents and Citations
- Jones v. Hendrix, 599 U.S. 465 (2023)
- Okereke v. United States, 307 F.3d 117 (3d Cir. 2002)
- United States v. Bartoli, 728 F. App’x 424 (6th Cir. 2018)
Practical Implications
This case serves as a critical reminder for federal prisoners regarding the limitations of habeas corpus petitions under § 2241. Key takeaways include:
- Understanding Jurisdiction: Federal prisoners must understand the jurisdictional boundaries of § 2241 versus § 2255.
- Procedural Compliance: It is essential for inmates to comply with procedural requirements when seeking relief from convictions.
- Ineffectiveness of § 2255: The ruling clarifies that merely being barred from filing a § 2255 motion does not automatically grant access to § 2241 relief.
This case highlights the complexities of federal habeas corpus law and the importance of following the appropriate legal channels for relief.
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Case Details
Legal case information
Status
Decided
Date Decided
June 10, 2025
Jurisdiction
F
Court Type
appellate
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools