Corbitt v. Jacquez, 2:19-cv-00549

Petitioner Bryan Corbitt, a federal inmate supervised in Seattle, filed a 28 U.S.C. § 2241 habeas petition seeking recalculation of good-conduct-time (GCT) credits under the First Step Act (FSA) of 2018.
The FSA amended 18 U.S.C. § 3624(b)(1) to allow up to 54 days of GCT per year; §102(b)(2) delayed implementation of §3624 amendments until 210 days after enactment (July 19, 2019).
Corbitt contends the amendment should apply immediately and that recalculation would yield roughly 49 additional days and an earlier release (approx. May 10, 2019).
Respondent (BOP) argued the petition is unripe because the amendment’s effective date had not arrived and that administrative remedies were not exhausted; several district courts had denied similar early petitions.
Magistrate Judge Mary Alice Theiler adopted reasoning from prior Reports and Recommendations (Judge Tsuchida) and recommended denying Corbitt’s petition because the FSA amendment had not become effective as of the petition date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness: can court order immediate recalculation before July 19, 2019?	Corbitt: amendment should take effect on enactment (Dec 21, 2018); waiting would moot relief.	BOP: petition is premature; amendment not yet effective.	Denied — petition is not entitled to relief based on the statutory delayed effective date.
Administrative exhaustion	Corbitt: exhaustion would be futile because BOP has predecided to deny requests until the effective date.	BOP: petitioner failed to exhaust administrative remedies.	Court agreed with prior analysis that exhaustion would be futile but still resolved on statutory effective-date grounds.
Merits: whether §102(b)(1) applies now	Corbitt: the new GCT calculation should apply immediately to his sentence.	BOP: statutorily delayed implementation prevents immediate application.	Held for BOP — amendment not in effect until July 19, 2019, so no immediate recalculation.
Constitutional claims (due process / equal protection)	Corbitt: delayed implementation violates due process/equal protection.	BOP: delay is lawful under the Act.	Rejected — court found no basis to invalidate the statutory effective-date delay.

No reported cases with official reporter citations were relied upon in this Report and Recommendation (the opinion principally adopts reasoning from unpublished district R&Rs in related cases).