Robinson v. Segal

Background

The First Step Act of 2018 provides incentives for federal prisoners to participate in evidence-based programs and productive activities. One incentive is time credits that may reduce the time a prisoner spends in custody. The statute provides 10 days of credits for every 30 days of successful participation, with an additional 5 days for certain prisoners who have minimum or low recidivism risk and whose risk has not increased over two consecutive assessments.

Alicia L. Robinson argued that the Bureau of Prisons had incorrectly calculated her credits. She contended that each eligible program she completed entitled her to a separate set of credits. Under her interpretation, participating in 10 programs could produce up to 150 credits in a month. The Bureau of Prisons interprets the law as awarding credits based on the number of days spent in eligible programming, not the number of programs attended.

Court’s Review

A magistrate judge recommended denying Robinson’s petition. Robinson objected. Because her objections repeated arguments made in her original petition, the district court reviewed them for clear error. The court also stated that it would not consider new evidence or new claims and arguments that Robinson had not presented to the magistrate judge.

The court agreed with the magistrate judge that the Bureau of Prisons’ interpretation was correct. It stated that courts considering the issue had agreed that First Step Act credits are based on the number of days spent in eligible programming during a 30-day period, not the number of eligible programs attended during that period.

Disposition

The court overruled Robinson’s objection, adopted the June 9, 2023 Report and Recommendation, and denied Robinson’s petition. The court entered judgment accordingly.