WASHINGTON — The U.S. Supreme Court heard arguments Monday in a case that could determine whether federal prisoners can use habeas corpus petitions to challenge the Bureau of Prisons when earned time credits under the First Step Act are not applied toward earlier transfers to halfway houses or home confinement.
The case, Maxwell v. Dinis, raises questions about access to judicial review for incarcerated people who contend that federal prison officials have failed to properly apply credits earned through participation in rehabilitation and recidivism reduction programs.
The dispute concerns the legal mechanism available to challenge those decisions, rather than whether federal prisoners are permitted to earn credits under the First Step Act of 2018.
William Maxwell, a federal prisoner serving a 20-year sentence, sought transfer to a halfway house or home confinement based on credits he maintained he had earned under the law.
After pursuing the Bureau of Prisons’ administrative grievance process, Maxwell filed a habeas corpus petition under 28 U.S.C. Section 2241, which allows federal courts to consider certain challenges to the legality of an individual’s custody.
Maxwell argued that the Bureau of Prisons had failed to properly apply his earned credits and that he was entitled to serve part of his remaining sentence outside a traditional prison facility.
The federal district court rejected his petition, concluding that he had not exhausted the available administrative remedies for his First Step Act claims.
The U.S. Court of Appeals for the Fifth Circuit affirmed the dismissal on different grounds, holding that Maxwell’s request did not qualify for habeas relief because a transfer to a halfway house or home confinement would not necessarily shorten his sentence.
The Fifth Circuit’s reasoning distinguished between challenges seeking release from custody and those involving the conditions or location of confinement.
That distinction became the central issue before the Supreme Court during oral arguments Nov. 2.
Congress enacted the First Step Act in 2018 to expand rehabilitative programming and create incentives for eligible federal prisoners to participate in evidence-based recidivism reduction programs and productive activities.
Under 18 U.S.C. Section 3632(d)(4), eligible prisoners generally earn 10 days of time credits for every 30 days of successful participation in qualifying programs.
Individuals who satisfy additional risk-assessment requirements may earn another five days of credits for every 30 days of participation.
The credits may be applied toward prerelease custody or supervised release when prisoners meet the statutory requirements outlined in 18 U.S.C. Section 3624(g).
Prerelease custody can include placement in a residential reentry center, commonly known as a halfway house, or home confinement.
Although the law provides opportunities to earn credits, eligibility for transfer depends on additional statutory conditions, including risk assessments and other requirements administered by the Bureau of Prisons.
Maxwell’s attorneys argued that habeas corpus is not limited to petitions seeking immediate release from all forms of custody.
Attorney Masha G. Hansford, representing Maxwell, maintained that the federal habeas statute permits challenges when a prisoner is being held in a more restrictive form of custody than federal law authorizes.
Under that interpretation, a prisoner who should have been transferred from a federal prison to home confinement or a halfway house could seek habeas relief even if the transfer would not reduce the overall sentence.
The federal government took a position that differed from the Fifth Circuit’s ruling.
Assistant to the Solicitor General Kevin J. Barber appeared on behalf of the respondent, Sandra Dinis, the acting warden, and supported vacating the lower court’s judgment.
The government largely agreed that a habeas petition could be an appropriate means of challenging the failure to apply First Step Act credits toward prerelease custody, although it raised separate procedural and jurisdictional objections concerning Maxwell’s case.
Because neither party defended the Fifth Circuit’s reasoning, the Supreme Court appointed attorney Brian W. Barnes to argue in support of the judgment below.
Barnes defended the distinction between challenges to the duration of custody and disputes involving where a prisoner serves a sentence.
The arguments required the justices to consider whether moving from a federal prison to a halfway house or home confinement constitutes a sufficiently significant change in custody to support habeas relief.
The Court’s 1973 decision in Preiser v. Rodriguez established that incarcerated people seeking restoration of good-time credits that would result in earlier release must pursue habeas proceedings rather than ordinary civil rights litigation.
The question in Maxwell’s case is whether that reasoning also applies when earned credits would accelerate a transfer to a less restrictive form of custody rather than immediately end the sentence.
The case also involves the relationship between the First Step Act and federal statutes governing the Bureau of Prisons’ authority to determine where incarcerated people serve their sentences.
Under 18 U.S.C. Section 3621(b), the Bureau of Prisons generally has broad discretion to designate a prisoner’s place of imprisonment, and certain placement decisions are excluded from judicial review under the Administrative Procedure Act.
However, Maxwell’s claim concerns the application of statutory earned time credits, raising the question of whether that authority limits judicial review when a prisoner alleges that the agency has failed to comply with federal law.
The justices also confronted a separate procedural complication during oral arguments involving whether Maxwell’s anticipated release from prison could make the dispute moot before the Court resolves the underlying legal question.
The government raised concerns about whether a decision in Maxwell’s favor would provide meaningful relief given his approaching release date.
That issue could affect whether the Supreme Court reaches the broader question of habeas jurisdiction or resolves the case on narrower grounds.
The outcome could have implications for federal prisoners who believe the Bureau of Prisons has incorrectly calculated or applied their First Step Act credits.
A ruling allowing such claims under Section 2241 could preserve a judicial avenue for prisoners seeking to challenge allegedly unlawful delays in transfers to prerelease custody.
Such a ruling would not automatically entitle prisoners to transfer or eliminate statutory eligibility requirements. Courts would still need to evaluate whether the credits were properly earned and whether the individual qualified for the requested relief.
Conversely, a decision restricting habeas review could require prisoners to pursue alternative legal remedies when challenging certain Bureau of Prisons placement decisions, potentially raising additional procedural obstacles.
The Supreme Court heard arguments Nov. 2 in Maxwell v. Dinis, No. 25-5930. No decision has been issued.
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