The U.S. Court of Appeals for the Ninth Circuit affirmed a district court's denial of a habeas corpus petition filed by federal prisoner Steven Hadley Hassan in *Hassan v. Wingfield*, rejecting his challenge to exclusions under the First Step Act. The unpublished memorandum opinion, filed Jan. 9, 2026, upholds strict interpretation of the federal prison reform law's eligibility requirements.
Hassan, an inmate at the Federal Correctional Institution in Marianna, Florida, filed a petition for a writ of habeas corpus against B. Wingfield, the acting warden. The case originated in the U.S. District Court for the District of Arizona under Judge John Charles Hinderaker, who initially denied Hassan's petition.
The appeal centered on Hassan's exclusion from earning time credits under the First Step Act, a 2018 federal prison reform law designed to reduce recidivism and provide incentives for prisoner rehabilitation. The Act offers various benefits to encourage inmates' participation in recidivism reduction programs, including enhanced phone and visitation privileges, transfers to institutions closer to inmates' release residences, increased commissary spending limits and expanded product offerings, and most significantly, time credits that can reduce sentences.
However, the First Step Act contains specific exclusions that bar prisoners convicted of certain offense categories from earning time credits. Under 18 U.S.C. § 3632(d)(4)(A) and (D), various serious offenses render inmates ineligible for these benefits. The court opinion indicates that Hassan's convictions fall within these excluded categories, though the specific nature of his offenses is referenced but not fully detailed in the available portion of the decision.
The Ninth Circuit panel, consisting of Circuit Judges Johnnie B. Rawlinson, Michelle T. Friedland (M. Smith), and Ryan D. Nelson (Bress), applied de novo review to both the denial of the habeas petition and the underlying questions of law. This standard of review indicates that the case involved pure legal questions rather than factual disputes, allowing the appeals court to examine the district court's legal conclusions without deference.
The court cited *Gonzalez v. Herrera*, 151 F.4th 1076, 1080 (9th Cir. 2025), as precedent for the review standard applied in habeas corpus cases involving First Step Act challenges. This citation suggests a pattern of similar cases reaching the circuit court level as prisoners test the boundaries of the Act's eligibility requirements.
The decision was issued as an unpublished memorandum, meaning it does not create binding precedent except as provided by Ninth Circuit Rule 36-3. The panel unanimously concluded that the case was suitable for decision without oral argument, as permitted under Federal Rule of Appellate Procedure 34(a)(2). Such procedural decisions typically indicate that the legal issues were considered straightforward or well-settled.
The case reflects ongoing litigation surrounding the First Step Act's implementation and interpretation. Since the law's passage in 2018, federal courts have addressed numerous challenges from inmates seeking to qualify for time credits or other benefits. The Act's specific exclusions for certain offense categories have been a particular source of litigation, as prisoners argue for narrower interpretations of the disqualifying provisions.
Hassan's case demonstrates the strict approach federal courts have taken toward the Act's eligibility restrictions. Rather than adopting expansive interpretations that might include more prisoners in the benefits program, courts have generally adhered to the plain language of the statute's exclusions.
The timing of the decision, submitted Jan. 7, 2026, and filed two days later, reflects the expedited nature of the court's handling of the case. The relatively quick turnaround from submission to decision suggests the panel found the legal issues clear-cut.
For Hassan, the affirmance means his exclusion from First Step Act time credits remains in place. He cannot earn the sentence reductions that might have shortened his federal prison term or qualify for the enhanced privileges available to eligible inmates participating in recidivism reduction programs.
The broader implications of the decision reinforce the limited scope of First Step Act benefits for inmates with certain types of convictions. The court's affirmance adds to the body of precedent supporting strict enforcement of the Act's exclusionary provisions.
While the full details of Hassan's underlying convictions are not available in the published portion of the decision, the court's reference to specific subsections of the First Step Act indicates his offenses fall within categories Congress determined should remain ineligible for time credit benefits.
The case number 24-6785 indicates Hassan filed his appeal in 2024, suggesting the lower court proceedings occurred relatively recently. The original district court case number 4:23-cv-00510-JCH shows the habeas petition was filed in 2023, reflecting the typical timeline for federal habeas corpus proceedings.
As federal prisons continue implementing First Step Act programs, similar challenges from excluded inmates are likely to continue reaching the appellate level, with courts consistently applying the statute's express limitations on eligibility for sentence reduction benefits.