Charles Crenshaw v. Warden, Lorain Corr. Inst.

── Charles Crenshaw v. Warden, Lorain Corr. Inst. ── Court: Court of Appeals for the Sixth Circuit Date: April 28, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0190n.06 Case No. 25-3458 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Apr 28, 2026 ) CHARLES CRENSHAW, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE NORTHERN WARDEN, LORAIN CORRECTIONAL ) DISTRICT OF OHIO INSTITUTION; WARDEN, BELMONT CORRECTIONAL INSTITUTION; WARDEN, ) FEDERAL CORRECTIONAL INSTITUTION ) PETERSBURG LOW, ) Defendants-Appellees. ) OPINION ) Before: READLER, DAVIS, and BLOOMEKATZ, Circuit Judges. DAVIS, Circuit Judge. Plaintiff Charles Crenshaw’s thirty-year prison sentence was reduced in May 2019, but he was not released from federal prison until over a year later, when he was transferred to state custody for a parole violation. Claiming that his continued detention after his sentence reduction violated his constitutional rights as well as state and federal tort law, Crenshaw sued the wardens of three prisons where he was housed. The district court dismissed Crenshaw’s complaint for failure to state a claim, and he appeals the dismissal. We affirm. I. In 1995, while on parole for a 1969 murder conviction, Charles Crenshaw was arrested in the Northern District of Ohio on federal drug and firearm charges. In September 1996, a jury found him guilty of possession with intent to distribute cocaine and possession of a firearm by a No. 25-3458, Crenshaw v. Warden, Lorain Correctional Institution, et al convicted felon. Crenshaw was sentenced to 360 months (30 years) in prison. Roughly twenty- three years into his sentence, Crenshaw successfully moved to reduce his term of imprisonment under the First Step Act of 2018, Pub. L. No. 115-391, § 404(b), 132 Stat. 5194, 5222 (2018). And, on May 7, 2019, the district court lowered his sentence to 281 months. In the meantime, the state of Ohio filed with federal authorities a detainer on Crenshaw for a parole violation. Crenshaw remained in federal custody until June 30, 2020, when he was transferred to state custody to answer for his parole violation. Asserting that federal authorities should have released him from custody in May 2019 when the district court ordered his sentence reduced, Crenshaw filed an administrative claim for damages under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 1346(b), 2671–2680. The Federal Bureau of Prisons (“BOP”) denied the April 21, 2021, claim and advised him of his right to sue on September 29, 2021. Specifically, the denial notice advised Crenshaw that he could “file suit in the appropriate United States District Court not later than six (6) months after the date of mailing of this notification.” (Right-to-Sue Ltr., R. 23-1, PageID 140). Roughly two and a half years later, on March 15, 2024, Crenshaw filed this action against the wardens of Lorain and Belmont Correctional Institutions (“State Defendants”) and the warden of Federal Correctional Institution (“FCI”) Petersburg Low. He brought claims for (1) wrongful det