---
title: "Miles v. Bowers"
citation: "Miles v. Bowers, No. 25-1291 (1st Cir. Apr. 27, 2026)"
authority_id: "AUTH-CA1-MILES-BOWERS-2026"
authority_type: "case"
jurisdiction: "federal_first_circuit"
precedential_status: "binding_in_ca1"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA1-MILES-BOWERS-2026/"
legal_review: "2026-10-15"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# Miles v. Bowers

## Holding or rule used

The view in former 28 C.F.R. § 523.42(a) that a sentence commences for time-credit purposes upon arrival at the designated facility conflicts with the text of the First Step Act.

## Material limitation

Cited here only for its holding on former § 523.42(a), which the Bureau then amended.

## Official source and pinpoints

Miles v. Bowers, No. 25-1291, slip op. at 14 (1st Cir. Apr. 27, 2026), CourtListener: <https://www.courtlistener.com/opinion/10848657/miles-v-bowers/>


## Used in

- [18 U.S.C. § 3632 — First Step Act Time Credits](https://jason93.com/legal/federal-process/modules/80-sentence-execution-and-bop/first-step-act-time-credits.md)