The U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of federal prisoner Julian Walker's habeas corpus petition in a brief memorandum decision filed Jan. 2, 2026. Walker challenged the Bureau of Prisons' implementation of earned time credits under the First Step Act of 2018.

Walker, representing himself pro se, filed the petition under 28 U.S.C. § 2241 in the U.S. District Court for the District of Arizona, where Judge Susan R. Bolton presided over the case. The Ninth Circuit panel, consisting of Circuit Judges Richard Paez, Michelle Friedland, and Lucy Koh, reviewed the district court's dismissal and affirmed the lower court's judgment.

The case centered on Walker's challenge to the Bureau of Prisons' policies regarding earned time credits established under the First Step Act of 2018. Walker contended that the FSA requires the BOP to apply earned time credits to all inmates who demonstrate reduced recidivism risk, including those assessed with medium recidivism risk scores like himself.

Walker specifically argued that the Bureau was improperly 'banking' his earned credits rather than applying them toward early release, and that the agency's practice of limiting such credits primarily to low-risk inmates violated the statutory framework. The district court dismissed Walker's petition, and the Ninth Circuit's affirmance upheld that the First Step Act's earned time credit provisions apply only to specific categories of federal prisoners as defined by the statute.