This week covers several issues: a court was forced to reconsider how the BOP calculates First Step Act credits now that it no longer gets automatic deference, a terminally ill prisoner was denied compassionate release twice before finally getting relief, a court held that withdrawing a guilty plea may require an evidentiary hearing instead of relying only on the plea transcript, and a firearm conviction was overturned because an officer turned a routine traffic stop into an unrelated criminal investigation.
Benson v. Warden FCI Edgefield, No. 24-6713, 2026 LX 174550 (4th Cir. Apr. 22, 2026)
Loper Bright Changes the Rules on FSA Credits
The Fourth Circuit remanded this case for one main reason: the legal landscape has changed, and courts can no longer simply accept the BOP’s interpretation of the First Step Act. The district court originally dismissed the petition by relying on the BOP’s rule that “successful participation” requires a prior risk and needs assessment. That was standard practice under Chevron, where courts deferred to agency interpretations. But Chevron is gone. Under Loper Bright, courts must now decide for themselves what the statute actually means. That matters here because the statute says a prisoner can earn credits once their sentence begins—and a sentence begins when a person is taken into custody, not when they arrive at their designated BOP facility. The BOP’s policy effectively adds a requirement that isn’t in the law, and now courts have to take a hard look at whether that policy is valid.
This shift is bigger than this one case. For years, challenges to BOP policies like this went nowhere because courts defaulted to “that’s how the agency interprets it.” That shortcut is no longer available. Now, if the BOP’s rules conflict with the actual text of the statute, courts have to say so. That gives prisoners a real opening to challenge how FSA credits are calculated, especially in situations like delayed transfers, time spent in county facilities, or programming completed before a formal assessment. This doesn’t guarantee anyone credits, but it forces courts to engage with the argument instead of dismissing it outright, and that alone is a meaningful change.
United States v. Glover, No. 3:14-240-JFA, 2026 LX 107421 (D.S.C. Apr. 16, 2026)
Terminally Ill Prisoner Denied Twice Before Finally Getting Compassionate Release
The court finally granted compassionate release to a terminally ill prisoner, but only after denying him twice before. On his third attempt, the record finally forced the issue. The government did not even dispute that he met the standard for a terminal condition, with a life expectancy of less than 18 months and severe, worsening health issues requiring near-constant care. Still, the government argued he should remain in prison based on the § 3553(a) factors, pointing to decades-old drug convictions and the seriousness of his offense. That argument went so far as to claim a man confined to a wheelchair, dependent on oxygen, and facing end-stage lung disease could somehow still pose a danger to the public. The court ultimately rejected that position, noting that his age, medical condition, and low risk scores made future criminal conduct highly unlikely.
What stands out here is how long it took to get relief even after the court had already recognized serious medical issues in an earlier motion. The first time, the court agreed his health was bad but said the sentencing factors outweighed it. Only after his condition deteriorated further did the balance finally shift. This is a reminder that compassionate release is often not a one-shot deal. Conditions change, records develop, and what gets denied once may be granted later. Courts are supposed to conduct an individualized assessment each time, and this case shows that persistence matters, especially when the facts continue to get worse and the government keeps pushing arguments that don’t match reality.
United States v. Clark, No. 24-4068, 2026 LX 127393 (6th Cir. Apr. 16, 2026)
Court Must Hold Hearing When Defendant Challenges Validity of Guilty Plea
The Sixth Circuit vacated the denial of a motion to withdraw a guilty plea, holding that the district court abused its discretion by refusing to hold an evidentiary hearing where the defendant raised real factual disputes about whether his plea was knowing and voluntary. The defendant argued that his attorney failed to show him the evidence, failed to explain the consequences of the plea, and failed to disclose his own disciplinary problems. He also pointed to a rushed plea hearing, including signing the agreement during the hearing and leaving a page uninitialed. The district court denied the motion based largely on the plea colloquy and the government’s version of events, but the appellate court made clear that was not enough. When a defendant raises specific factual disputes that go to the validity of the plea, especially involving ineffective assistance, cannot rely solely on the transcript of the plea hearing and must hold an evidentiary hearing to resolve those issues.
United States v. Martin, No. 25-4233, 2026 U.S. App. LEXIS 10979 (4th Cir. Apr. 17, 2026)
Stop for Traffic Violation Turns into Unrelated Gun Investigation, Evidence Suppressed
The Fourth Circuit reversed and suppressed the evidence because the officer immediately abandoned the purpose of the traffic stop and turned it into a criminal investigation. The stop was for parking on a bridge, but instead of addressing that violation, the officer led with questions about firearms and “anything else” in the vehicle. The court emphasized that these questions had nothing to do with the reason for the stop and were not justified by any safety concern. Unlike cases where brief safety questions are allowed, the officer here made firearms the focus from the very beginning, never returned to the traffic violation, and didn’t even issue a citation. That shift, from a traffic stop to an unrelated criminal investigation, violated the Fourth Amendment and required suppression of the firearms and statements obtained as a result.
Dale Chappell works with individuals, families, and attorneys on sensitive and high-profile federal cases, focusing on prison preparation, housing, and post-conviction strategy. He supports clients and legal teams with research, issue analysis, and drafting used in federal post-conviction matters, including § 2255 motions, appeals, sentence reductions, and related filings.
His work is based on nearly 17 years of experience and more than 450 published articles in legal publications focused on post-conviction relief. His focus is helping clients and their families understand how the system actually works and avoiding preventable mistakes.
Have questions?
Email Dale directly at dale@dale-chappell.com.
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