Adebola Olumbunm Ajala v. United States Parole Commission

Adebola Olumbunm Ajala, who was convicted in England and transferred to the United States to serve the remainder of her sentence, challenges the determination of the United States Parole Commission (“Commission”) establishing her release date pursuant to 18 U.S.C. § 4106A. Ajala claims that the Commission erred in two respects. First, the Commission failed to account for good time credit earned while she was incarcerated in England and which may be earned during her incarceration in the United States. Second, the Commission denied a downward adjustment in her offense level for her allegedly minimal or minor role in the offense. We conclude that we have jurisdiction over the latter determination, but not over the former. We affirm the latter, and dismiss the appeal as to the former.

BACKGROUND FACTS

Ajala is an American citizen. On May 15, 1990, Ajala was arrested by British customs officials as she deplaned in London from Nigeria. The officials noticed that she had laxatives in her bag. Two urine samples taken from Ajala tested positive for opiates. She subsequently excreted 89 packages containing 238.8 grams of heroin. Ajala claims that her “uncle,” Tony Falano, preyed upon her…