Inmate Who Filed Own Appeal Gets Supreme Court Review

The US Supreme Court agreed to hear an appeal from a Texas inmate who represented himself in his initial appeal to the justices seeking transfer from prison to less restrictive custody.

The justices on Monday granted William Maxwell’s petition that he was wrongly denied good time credit under the First Step Act that would have allowed him to leave prison early and finish his sentence at a halfway house or on home confinement.

Maxwell is challenging a bright-line rule of the US Court of Appeals for the Fifth Circuit separating civil rights suits and habeas petitions. Under its own precedent set in Melot v. Bergami, the appellate court held habeas relief was unavailable to Maxwell unless success would automatically shorten his sentence, rather than change his level of custody.

The case asks whether disputes over the calculation of First Step Act time credits that would enable an inmate to transfer earlier to a halfway house or home confinement are actionable under the federal habeas statute. Maxwell argues the Fifth Circuit’s holding defies Supreme Court precedent and splits with nine other circuits.

Maxwell, who is serving a 20-year sentence for racketeering at the low-security federal facility in Beaumont, Texas, is the rare pro se litigant to have his case taken up by the Supreme Court. Davis Polk partner Masha Hansford and attorneys from Paul Weiss filed a reply brief on Maxwell’s behalf after the justices requested a response from the government.

The Trump administration agreed the Fifth Circuit’s ruling was “inconsistent” with the habeas limits defined in the Supreme Court’s 2023 decision in Jones v. Hendrix, but argued the case was a poor vehicle due to disagreements within the circuit and Maxwell’s failure to exhaust his administrative remedies.

The court has weighed in repeatedly on the limits of the First Step Act since the bipartisan criminal reform law was passed in 2018—most recently this term, when it took up two cases dealing with the law’s expansion of compassionate release.

The case is Maxwell v. Thomas, U.S., No. 25-5930.