Motion Requesting a Judicial Recommendation for Maximum Halfway House Placement — United States v. Gregory Scott Keough

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Case 9:23-cr-80154-DMM Document 66 Entered on FLSD Docket 09/30/2024 Page 1of5
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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDAF|LED BY co D.C.

UNITED STATES OF AMERICA

Plaintiff(s)

SEP 30 2024

ANGELA E. NOBLE
CLERK U.S. DIST. CT.
S.D. OF FLA. — W.P.B.

V. Criminal Case: 9:23CR80154-DMM

GREGORY SCOTT KEOUGH
BOP Inmate No. 72151-510

Defendant

MOTION REQUESTING A JUDICIAL RECOMMENDATION FOR MAXIMUM

HALFWAY HOUSE PLACEMENT

COMES NOW, the Defendant, Gregory Keough, pro se and unskilled in the field of law,

and respectfully moves this Honorable Court to recommend that the Bureau of Prisons (“BOP”)

_ afford the Defendant the maximum Residential Re-entry Center (“RRC”)/halfway house

placement time of 12 months preceding the end of his sentence. In support thereof, Defendant

states as follows:

1. Defendant was sentenced by this Court to a term of (3 0) months imprisonment followed

by a term of (3) years of supervised release.

2. Pursuant to the Second Chance Act of 2007 (“SCA”) the BOP may place a defendant into

RRC/halfway house up to twelve months prior to his release date if it is determined that

his placement in a halfway house is of “sufficient duration to provide the greatest

likelihood of successful reintegration into the community.”

3. The criteria that the Bureau of Prisons is to consider in assessing an individual applicants’

eligibility for up to twelve months of RRC/Halfway House are: any statement made by

Case 9:23-cr-80154-DMM Document 66 Entered on FLSD Docket 09/30/2024 Page 2 of 5

the Court concerning the purposes that warranted a sentence to imprisonment and
recommending the type of correctional facility that would be appropriate. 18 U.S.C.
3621(b)(4)(A), (B). The BOP is soliciting an opinion from the Court recommending
early placement in a halfway house prior to release. An RRC/halfway house is a
correctional facility with superior transitional programs to help inmates rebuild their ties
to the community.

4. Movant is currently incarcerated at FPC Montgomery, Montgomery, AL. His release
date is February 21, 2026, and an RRC placement will not affect this.

5. According to Federal Bureau of Prisons’ Memorandum for Chief Executive Officers,
June 24, 2010, (see Exhibit 1: Revised Guidance for Residential Reentry Center
(RRC) Placements) Extended Pre-Release RRC/Halfway House time decisions “are to
focus on RRC placement as a mechanism to reduce recidivism.”

6. Movant is 57 years old. He can be reformed and rejoin law-abiding society with the help
available from prolonged placement at a federal halfway house.

7. The purpose of the Second Chance Act of 2007 is to improve the reintegration of
offenders back into their respective communities and to reduce recidivism. While
ultimately left to the discretion of the BOP, RRC/halfway house placement must be
(A) conducted in a manner consistent with section 3621(b) of this title;

(B) determined on an individual basis; and
(C) of sufficient duration to provide thé greatest likelihood of successful reintegration
into the community, 18 U.S.C. § 3624(c)(1)-(2).

8. The Attorney General of the United States and the Inspector General of the BOP have

noted in reports and public statements that the BOP is underutilizing various programs
Case 9:23-cr-80154-DMM Document 66 Entered on FLSD Docket 09/30/2024 Page 3 of5

available, such as RRC/halfway house. It should also be noted that generous

RRC/halfway house placement drastically reduces the cost of traditional incarceration.

WHEREFORE NOW, above premises considered, the defendant respectfully requests that
this Honorable Court GRANT this motion and all relief requested herein, issuing a judicial
recommendation to the BOP that the Defendant be granted the maximum placement time at a
federal halfway house, reflecting the same and granting all other relief required by Law, Liberty,

and Equity.

Done this 12th Day of September 2024.

Respectfully Submitted,

Py

GREGORY KOUGH #72151-510

FPC MONTGOMERY
MAXWELL AFB

MONTGOMERY, AL 36112
Case 9:23-cr-80154-DMM Document 66 Entered on FLSD Docket 09/30/2024 Page 4of5

CERTIFICATE OF SERVICE

I, the undersigned, do hereby certify that I have served a copy of this pleading upon the
Clerk of the Court, VIA US Mail, properly addressed, First-Class Postage prepaid. The accused

further requests that a copy of this pleading be forwarded to all parties, VIA the CM/ECF

System, as he is indigent, detained, and has no other means.

Done this 12th Day of September 2024,

Respectfully Submitted,

iC

GREGORY KEUGH472151-510

FPC MONTGOMERY

MAXWELL AFB

MONTGOMERY, AL 36112
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