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

Petitioner Bryan Corbitt is a federal inmate who challenged the Bureau of Prisons’ calculation of good-time credit under the First Step Act (which amended 18 U.S.C. § 3624(b)(1) to raise maximum annual credit from 47 to 54 days).
Corbitt argued the amendment entitled him to additional good-time days and an earlier release date effective upon enactment.
The Bureau of Prisons treated the amendment as taking effect only when the First Step Act’s risk-and-needs assessment system was established (July 19, 2019).
Magistrate Judge Theiler issued a Report & Recommendation (R&R) recommending dismissal of Corbitt’s § 2241 petition, adopting reasoning from a similar R&R by Magistrate Judge Tsuchida.
Corbitt objected, citing legislative history and arguing the R&R’s result was irrational.
After objections, the Ninth Circuit issued Bottinelli v. Salazar rejecting the same arguments and holding the amendment’s calculation took effect with establishment of the risk-and-needs assessment system; the district court adopted the R&R and dismissed Corbitt’s petition with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effective date of First Step Act’s amended good-time credit calculation	Corbitt: amendment took effect on enactment, entitling him to immediate additional good-time credit	BOP: amendment becomes effective only when the statutorily required risk-and-needs assessment system is established (July 19, 2019)	Court followed Ninth Circuit (Bottinelli): amendment effective upon establishment of the assessment system (July 19, 2019); Corbitt not entitled to earlier release

( No authoritative, officially reported decisions with Bluebook citations were cited in the opinion excerpt provided. )