Rahshjeem Benson v. Warden FCI Edgefield

── Rahshjeem Benson v. Warden FCI Edgefield ── Court: Court of Appeals for the Fourth Circuit Date: April 22, 2026 Category: General USCA4 Appeal: 24-6713 Doc: 48 Filed: 04/22/2026 Pg: 1 of 17 PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-6713 RAHSHJEEM BENSON, Petitioner – Appellant, v. WARDEN FCI EDGEFIELD, Respondent – Appellee. Appeal from the United States District Court for the District of South Carolina, at Rock Hill. Henry M. Herlong, Jr., Senior District Judge. (0:24-cv-01195-HMH) Argued: March 19, 2026 Decided: April 22, 2026 Before KING, AGEE, and HARRIS, Circuit Judges. Vacated and remanded by published opinion. Judge Agee wrote the opinion in which Judge King and Judge Harris joined. ARGUED: Claire Victoria Madill, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Greenbelt, Maryland, for Appellant. Todd Stuart Timmons, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee. ON BRIEF: James Wyda, Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Greenbelt, Maryland, for Appellant. Bryan P. Stirling, United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Columbia, South Carolina, for Appellee. USCA4 Appeal: 24-6713 Doc: 48 Filed: 04/22/2026 Pg: 2 of 17 AGEE, Circuit Judge: Rahshjeem Benson, a federal prisoner, was sentenced in December 2020. But he was not transferred to his designated Bureau of Prisons (BOP) facility—Federal Correctional Institution Edgefield (FCI Edgefield)—until March 2022. Prior to his arrival at FCI Edgefield, Benson alleges that he participated in First Step Act (FSA) programs and earned FSA credits which could expedite his pre-release custody or supervised release. Once Benson arrived at FCI Edgefield, the BOP administered a risk and needs assessment to determine the FSA programs best suited for a prisoner based on his risk of recidivism. But because Benson did not receive the assessment until he arrived at FCI Edgefield, the BOP refused to give him any credits he alleges that he previously earned. Benson filed a pro se habeas petition, requesting that the BOP award him the approximately 150 FSA credits he claims that he earned before arriving at FCI Edgefield. Without conducting discovery or requiring a response from the Government, a magistrate judge recommended dismissing his petition. The district court similarly declined to require a response from the Government, rejected Benson’s objections to the magistrate judge’s recommendation, and dismissed his petition. For the reasons that follow, we vacate and remand for additional proceedings consistent with this opinion. I. A. 2 USCA4 Appeal: 24-6713 Doc: 48 Filed: 04/22/2026 Pg: 3 of 17 Before discussing the factual background and procedural history, a brief recitation of the relevant statutory framework is in order. The FSA was designed to promote the release of federal prisoners who are less likely to recidivate and thereby reduce the federal prison population. White v. Warden of Fed. Corr. Inst. – Cumberland, 164 F.4th 326, 330 (4th Cir. 2025). Congress directed the Attorney General in the FSA to develop a “risk and needs assessment system” to be used by the BOP to (1) determine each prisoner’s risk of recidivism and risk of violent or serious misconduct; (2) assign t