Hill v. Bradley, 3:21-cv-01857

Petitioner Sheldon W. Hill is a federal inmate serving a 151‑month sentence (Bank Robbery), with projected release May 9, 2025 via good conduct time.
Hill filed a §2241 habeas petition asking the court to order the BOP to apply 915 hours of First Step Act (FSA) earned time credits (ETCs) for completed programming.
The BOP has performed seven First Step Act risk assessments since 2019; Hill was assessed as a high recidivism risk in each assessment.
Hill has completed at most 83 hours of programming to date; BOP records and policy state accrued credits cannot be applied until an inmate is a minimum or low recidivism risk.
The BOP submitted a declaration explaining statutory and regulatory requirements (including 18 U.S.C. §3624(g) and 28 C.F.R. §523.44) and noted Hill did not use the administrative remedy process or file a traverse.
The District Court denied the §2241 petition, concluding the statute precludes application of FSA time credits while Hill remains at high risk.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FSA earned time credits may be applied before an inmate is reassessed to low/minimum recidivism risk	Hill: BOP should apply 915 hours of ETCs for completed programs now	BOP: §3624(g) and implementing rules require a last reassessment (or two for prerelease) showing minimum/low risk before credits are applied	Court: Denied — statutory text bars applying credits until risk level is reduced to minimum/low
Whether habeas relief is appropriate given available BOP administrative remedies	Hill: seeks judicial relief to obtain application of credits (did not file traverse)	BOP: Hill had administrative remedies available and did not exhaust them; factual declaration supports BOP position	Court: Denied — primary basis statutory ineligibility; administrative remedy available and not pursued by Hill

None (the opinion did not cite any authorities with official reporter citations).