Rahshjeem Benson was sentenced in December 2020 and held at the Donald W. Wyatt Detention Center in Rhode Island before being transferred to FCI Edgefield in South Carolina in March 2022. During his time at Wyatt, Benson alleges he participated in First Step Act programs and earned approximately 150 days of time credits. However, upon arriving at FCI Edgefield, the Bureau of Prisons administered a risk and needs assessment and denied him any credits earned prior to that assessment, citing a regulation that defines successful participation as requiring a completed assessment. Benson filed a pro se habeas petition seeking the credits. The district court dismissed the petition without allowing discovery or requiring a government response, concluding that Benson could not have successfully participated before his assessment and that the BOP's regulation was a permissible interpretation of the law.
The Fourth Circuit addressed two primary issues. First, regarding mootness, the court rejected the government's claim that Benson's subsequent reclassification to a medium recidivism risk rendered the case moot. The court explained that the First Step Act allows prisoners with medium risks to still petition for transfer or qualify for credits through subsequent low-risk assessments, meaning a favorable court decision could provide immediate relief by clearing the path to accessing his alleged credits. Second, on the merits, the court vacated the dismissal because the district court failed to develop the factual record. The court noted that pro se pleadings must be construed liberally and that Benson had alleged participation and requested educational transcripts, which were never obtained. The district court had dismissed the case based on the BOP's regulatory definition of successful participation, which ties credit eligibility to the timing of the risk assessment. However, the court emphasized that the First Step Act statute defines when a sentence commences as the date the defendant is received in custody, not the date of arrival at the designated facility. Consequently, the statutory framework suggests eligibility begins upon custody, regardless of when the assessment occurs. The court further noted that the district court relied on Chevron deference, which the Supreme Court overturned in Loper Bright Enterprises v. Raimondo. Under Loper Bright, courts must exercise independent judgment rather than deferring to agency interpretations. Therefore, the court remanded the case for the district court to determine whether the BOP's interpretation of successful participation aligns with the single best meaning of the statute under the new legal standard.
The case returns to the district court, which must now conduct discovery to determine if Benson actually participated in First Step Act programs while at the Wyatt Detention Center. The district court must also re-evaluate the Bureau of Prisons' regulation defining successful participation without Chevron deference, applying the independent judgment standard required by Loper Bright. If the district court finds that the BOP's interpretation is inconsistent with the statute, it may order the BOP to award the credits Benson alleges he earned. The decision clarifies that a prisoner's eligibility for credits begins when their sentence commences in custody, not when they arrive at their designated facility, but factual proof of participation remains a necessary element.
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