Bradshaw v. Dahlstrom — 9th Cir. (argued August 13, 2026)
The Ninth Circuit hears Ryan Bradshaw's appeal from the dismissal of his damages suit against two Alaska corrections commissioners. When he was sentenced, Alaska gave probationers thirty days of credit for every thirty compliant days. A later law barred people convicted of felony assault from earning those credits. Bradshaw says applying that change to him extended his probation by eighteen months and violated the Ex Post Facto Clause, which bars retroactive increases in punishment. The district court dismissed the claim, finding that prior decisions had not clearly established the change as unconstitutional, and therefore gave the commissioners qualified immunity from damages. Bradshaw will rely on Supreme Court prison-credit cases; the commissioners will say those cases did not concern probation.
Bradshaw v. Dahlstrom (No. 25-4165) — U.S. Court of Appeals for the Ninth Circuit, argued August 13, 2026.
- 0:00Introduction
- 14:27Quantum of Punishment
- 24:21The Intent–Effects Test