Hogan v. FCI La Tuna Case Manager

<p>A federal appeals court affirmed the dismissal of a <strong>habeas corpus petition</strong> filed by prisoner Dennis Michael Hogan, who sought First Step Act time credits for the period between his sentencing and his arrival at his designated <strong>Bureau of Prisons</strong> facility. Hogan argued that he was entitled to accrue these credits during his pre-transfer detention, contending that <strong>Bureau of Prisons</strong> regulations improperly delayed his eligibility. The majority concluded that Hogan&#39;s claim failed because he did not substantiate any actual participation in <strong>recidivism reduction programs</strong>, which is a mandatory statutory prerequisite for earning time credits. In contrast, the dissenting judge argued that the case should be remanded because the <strong>Bureau of Prisons</strong> prevented Hogan from accessing required programming before his facility transfer, creating genuine disputes of material fact that precluded summary judgment.</p>