Sentence Computation Manual/Old Law/Pre CCCA 1984

By Elizabeth Franklin-Best, Esq., and Christopher Zoukis, JD, MBA

Program Statement	5880.30
Subject	Sentence Computation Manual (“Old Law” — Pre-CCCA-1984)
Current edition	09-08-1999 (Change Notice 4). The underlying Program Statement is dated July 16, 1993.
Change notices	Four. CN-01 (3/10/1994), CN-02 (7/18/1994), CN-03 (6/30/1997), CN-04 (9/8/1999)
Supersedes	P.S. 5880.20, Sentence Computation Manual (09/05/72), plus P.S. 1330.8, 5050.9, 5050.34, 5880.17, 5880.18, 5880.24, 5881.20 and O.M. 309-92
Governing statutes	18 U.S.C. §§ 4161–4166 (good time) and §§ 4201–4218 (parole), both repealed effective Nov. 1, 1987 but still governing offenses committed before that date; 18 U.S.C. § 3568 (presentence credit, repealed)
Governing regulation	28 C.F.R. §§ 523.1–523.17; 28 C.F.R. §§ 2.11, 2.12, 2.29, 2.52; 28 C.F.R. § 571.30
Related BP forms	BP-380 Good Time Record · BP-389 Statutory Good Time Action Notice · BP-390 Extra Good Time Recommendation
Official PDF	https://www.bop.gov/policy/progstat/5880_030.pdf

Checked against the BOP policy set · 2026-09-07 · How we verify

Program Statement 5880.30 is the Bureau of Prisons’ 238-page instruction manual for computing a federal sentence when the offense was committed before 1 November 1987 — the “old law,” pre-Guidelines regime of statutory good time, extra good time, and parole. If your family member was told “the sentencing guidelines don’t apply to him,” this is the manual that does, and the practical questions it answers are how many days of good time come off the sentence and when the U.S. Parole Commission has to consider him. If you are trying to turn that computation into an earlier release, start with our federal early release practice pages and with challenging a BOP sentence computation.

The single most important thing to understand: the statutes this manual applies were repealed, and they still control your case. Congress repealed 18 U.S.C. §§ 4161–4166 and §§ 4201–4218 in the Sentencing Reform Act of 1984, but made that repeal “effective Nov. 1, 1987, and applicable only to offenses committed after the taking effect of such repeal”, while preserving the old provisions for anyone who committed an offense before that date. A repealed statute is not a dead statute when the savings clause keeps it alive for you.

Who this manual covers

The dividing line is the date of the offense, not the date of sentencing, the date of arrest, or the date of the indictment. PS 5880.30 says so on its own first page of substance: “The instructions for computation of sentence contained in this manual pertain only to those offenses that occurred prior to November 1, 1987” (PS 5880.30 at p. 17). A person sentenced in 1994 for a 1985 offense is an old-law prisoner. A person sentenced in 1986 for a 1988 offense does not exist, but a person with counts on both sides of the line does — and that case is the hardest kind of computation the Bureau does, because old-law and Sentencing Reform Act sentences cannot be aggregated with each other.

Three groups of people are covered by this manual today:

• Federal prisoners whose offense conduct predates 1 November 1987, including people returned to custody as parole violators or mandatory-release violators on those sentences.
• D.C. Code offenders confined at the non-workhouse facilities at Lorton, or later transferred to the Bureau, whose offenses predate 11 April 1987 — the Bureau applied 18 U.S.C. §§ 4161–4166 to them, and the D.C. manual says so expressly (PS 5880.33 at p. 38). See D.C. Code sentence computation for how the two manuals hand off to each other.
• People serving foreign treaty transfer sentences, Youth Corrections Act sentences, Narcotic Addict Rehabilitation Act sentences, and juvenile dispositions from the pre-1987 era, each of which gets its own chapter in this manual.

Everyone else — every federal prisoner whose offense was committed on or after 1 November 1987 — is computed under the current sentence computation manual and earns good conduct time under 18 U.S.C. § 3624(b) instead. The regulation states the divide plainly: inmates sentenced under the Sentencing Reform Act for offenses on or after November 1, 1987 “are not eligible for either statutory or extra good time, but may be considered for a maximum of 54 days of good conduct time credit per year”.

The rule itself — the statutory good time rate table

This is the number people are looking for. Statutory good time (“SGT”) is credited in advance, when the sentence is first computed, at a rate fixed by the length of the sentence — not earned month by month the way modern good conduct time is. The Bureau reproduces the governing statute and then flattens it into a rate chart:

“Each prisoner convicted of an offense against the United States and confined in a penal or correctional institution for a definite term other than for life, whose record of conduct shows that he has faithfully observed all the rules and has not been subjected to punishment, shall be entitled to a deduction from the term of his sentence beginning with the day on which the sentence commences to run, as follows:

Five days for each month, if the sentence is not less than six months and not more than one year.

Six days for each month, if the sentence is more than one year and less than three years.

Seven days for each month, if the sentence is not less than three years and less than five years.

Eight days for each month, if the sentence is not less than five years and less than ten years.

Ten days for each month, if the sentence is ten years or more.”

Statutory good time chart

Length of sentence	Statutory good time rate
0 to 6 Months	0 Dys
6 Months to 1 Year and 1 Day	5 Dys Per Mo
1 Year and 1 Day to 3 Years	6 Dys Per Mo
3 Years to 5 Years	7 Dys Per Mo
5 Years to 10 Years	8 Dys Per Mo
10 Years and More	10 Dys Per Mo

Reproduced verbatim from Program Statement 5880.30 at p. 34 (Chapter IV, Page 1), quoting 18 U.S.C. § 4161 (repealed as to offenses committed on or after Nov. 1, 1987).

The manual then converts those rates into total days for the sentence lengths courts actually imposed. This second chart is the one that answers “how many days does he get” without arithmetic:

Statutory good time for often imposed sentences

Sentence	Total statutory good time
180 Days (never equals 6 months)	0 Days
6 Months (5 Days Per Month)	30 Days
1 Year (5 Days Per Month)	60 Days
1 Year and 1 Day (6 Days Per Month)	72 Days
2 Years (6 Days Per Month)	144 Days
3 Years (7 Days Per Month)	252 Days
4 Years (7 Days Per Month)	336 Days
5 Years (8 Days Per Month)	480 Days
6 Years (8 Days Per Month)	576 Days
7 Years (8 Days Per Month)	672 Days
8 Years (8 Days Per Month)	768 Days
9 Years (8 Days Per Month)	864 Days
10 Years (10 Days Per Month)	1200 Days

Reproduced verbatim from Program Statement 5880.30 at p. 35 (Chapter IV, Page 2).

Two features of this table trip people up every time. First, “180 Days (never equals 6 months) = 0 Days” — a 180-day sentence is not a six-month sentence for good-time purposes, so it earns nothing. Second, the one-day jump: a sentence of “1 year and 1 day” earns 72 days where a flat one-year sentence earns 60, because the extra day moves the sentence into the six-days-per-month tier. That is not a rounding quirk; it is the reason experienced defense counsel asked for “a year and a day” in the old-law era.

For partial months the manual gives a formula, not a table: “Days x rate ÷ 30 = Days SGT for Partial Month (fractions are dropped)” (PS 5880.30 at p. 35). Fractions are dropped, never rounded up.

Extra good time — the second lever, and the one people forget

Statutory good time is automatic and rate-driven. Extra good time (“EGT”) is separate, is earned by assignment, and stacks on top. It is authorized by 18 U.S.C. § 4162 and implemented at 28 C.F.R. §§ 523.10–523.17, which are still in the Code of Federal Regulations today.

The rate is set by seniority, and the regulation the manual reproduces defines it in one sentence:

“‘Seniority’ refers to the time accrued in an extra good time earning status. Twelve months of ‘seniority’ automatically causes the earning rate to increase from three days per month to five days per month and seniority is then vested.”

Reproduced verbatim from Program Statement 5880.30 at p. 180 (Chapter XIII, Page 2), quoting 28 C.F.R. § 523.1(c).

So the EGT rate is three days per month, rising to five days per month after twelve months of accrued seniority. Six categories of extra good time exist under the regulation — meritorious good time (MGT), work/study release good time, community corrections center good time, industrial good time (IGT), camp or farm good time (CGT), and lump sum awards. The rules that matter most:

• Only one type at a time. The regulation provides that an inmate “may earn only one type of extra good time award at a time”, except that a lump sum award may be given in addition to another award.
• Some types are automatic; one is not. Industrial, camp/farm, work/study release, and community corrections center good time are awarded automatically on assignment. Meritorious good time is not — it requires a work supervisor’s recommendation with a written justification, approved by the Warden or designee (PS 5880.30 at p. 181).
• Lump sum awards are capped. “The Warden may make lump sum awards of extra good time not to exceed thirty days,” with anything larger referred to the Regional Director (PS 5880.30 at p. 183). The five listed grounds are an act of heroism; voluntary acceptance and satisfactory performance of an unusually hazardous assignment; an act protecting lives or U.S. property; a suggestion producing substantial improvement or significant savings; or any other exceptional or outstanding service (PS 5880.30 at p. 184).
• EGT vests and cannot be taken back. The regulation states that “Once extra good time is awarded, it becomes vested and may not be forfeited or withheld, or retroactively terminated or disallowed” — and separately that the Warden and the Discipline Hearing Officer “may not forfeit or withhold extra good time.” What they can do is disallow it for one calendar month, or terminate it going forward.
• Seniority survives a sentence that cannot use it. A person serving a Youth Corrections Act or Sentencing Reform Act sentence who works in industries accrues seniority toward a later old-law sentence even though no EGT days are credited to the sentence being served (PS 5880.30 at p. 190). That is a real and frequently missed argument.
• Seniority does not survive revocation. “The beginning rate of EGT for a parole or mandatory release violator will be at the three day rate and the prisoner must gain twelve months of seniority while serving the violator term prior to advancing to the five day rate” (PS 5880.30 at p. 187).

Statutory good time, by contrast, can be forfeited. The manual reproduces 18 U.S.C. § 4165 — “If during the term of imprisonment a prisoner commits any offense or violates the rules of the institution, all or any part of his earned good time may be forfeited” — and § 4166’s restoration authority, which the Attorney General has delegated to the Director and the Director has redelegated to Wardens. Every forfeiture, withholding, and restoration is documented on a BP-389, Statutory Good Time Action Notice, completed by the Discipline Hearing Officer (PS 5880.30 at p. 37). If a computation looks wrong after a disciplinary hearing, the BP-389 is the document to ask for. See inmate discipline for how those hearings run.

Parole eligibility — the third lever

Old law means parole, and parole eligibility is set by the sentencing provision the judge used, not by the Bureau. The manual walks through each one, quoting the repealed statute in each case. The four that matter:

Sentencing provision	When the person becomes parole eligible
18 U.S.C. § 4205(a) — the default	After serving one-third of the term, “or after serving ten years of a life sentence or of a sentence of over thirty years”
18 U.S.C. § 4205(b)(1) — court-set minimum	At the court-designated minimum term, which “may be less than but shall not be more than one-third of the maximum sentence imposed”
18 U.S.C. § 4205(b)(2) — Commission’s discretion	Immediately eligible; the Bureau’s SENTRY system enters “COMMISSION’S DISCRETION” in the parole eligibility field
18 U.S.C. § 4206(d) — mandatory parole	After two-thirds of each consecutive term, or thirty years of a term over forty-five years including life — whichever is earlier, for sentences of five years or longer

Compiled from Program Statement 5880.30 at pp. 63, 66, 68 and 70 (Chapter VII, pp. 6, 9, 11 and 13), which quote the statutory text of each provision. Verified against former 18 U.S.C. § 4205.

The ten-year cap in § 4205(a) is worth understanding. A sentence of more than one year up to and including thirty years becomes parole eligible at one-third; a sentence over thirty years, including life, becomes eligible at ten years (PS 5880.30 at p. 63). The manual also records that as of its issuance, the Eighth, Ninth, Tenth and Eleventh Circuits had held that a court-imposed minimum term under § 4205(b)(1) may exceed the ten-year cap so long as it does not exceed one-third of the maximum (PS 5880.30 at p. 66). That is a circuit split the Bureau documented in 1993 and never resolved in policy; it is worth checking the law of the sentencing circuit before assuming the cap applies.

Parole eligibility is not release. Under § 4206(d), even mandatory parole carries a proviso: the Commission “shall not release such prisoner if it determines that he has seriously or frequently violated institution rules and regulations or that there is a reasonable probability that he will commit any Federal, State or local crime” (PS 5880.30 at p. 70). A 2025 report and recommendation in the District of South Carolina collected the cases on that point, holding that where a § 4206(d) hearing is late or has not happened, “the appropriate remedy is not the release of the inmate, but to hold a § 4206 hearing as soon as possible.” Williams v. Warden of Bennettsville FCI, No. 5:24-cv-00585 (D.S.C. Jan. 3, 2025).

How good time turns into an actual release — and what kind

Old law produces three different release types, and which one a person gets depends on how many days of good time they have, not on anything the Bureau chooses. The manual sets the rule out under 18 U.S.C. §§ 4163–4164:

• Mandatory Release (MR). “Under the provisions of 18 USC § 4164, any person who attains an SRD, based on any combination of good time (SGT and/or EGT), that equals more than 180 days, shall be mandatorily released as if on parole. Such person is under parole supervision up to 180 days before the EFT date.”
• Expiration of Sentence Full Term (Exp.FT). “Any person who accumulates no good time (SGT and/or EGT) is released unconditionally from confinement with no supervision to follow.”
• Expiration of Sentence Good Time (Exp.GT). “Any person who accumulates 180 days or less of any combination of good time (SGT and/or EGT) is released unconditionally from confinement with no supervision to follow.”

Reproduced verbatim from Program Statement 5880.30 at p. 61 (Chapter VII, Page 4).

This is why the “180 day date” appears on an old-law computation sheet. The Bureau calculates it precisely so staff can identify who leaves with parole supervision attached and who walks out clean. The manual’s own example is the clearest statement of the stakes: “a person who earns 144 days SGT plus 37 days EGT for a total of 181 days good time, will be released by MR, as if on parole, with one day of supervision to follow” (PS 5880.30 at p. 62). One day over the line changes an unconditional release into years of supervision.

Good time is subtracted from the expiration full term date to produce the statutory release date. It does not move the parole eligibility date, and it does not move the two-thirds mandatory parole date. The Williams court put it directly: the BOP applies statutory good time credits “to the end of Petitioner’s full term release, not his two-thirds parole date,” and “statutory good time credits do not count towards an inmate’s mandatory parole/two-thirds date.” Williams v. Warden of Bennettsville FCI, No. 5:24-cv-00585 (D.S.C. Jan. 3, 2025). Confusing those two dates is the single most common error we see in old-law correspondence.

What old-law sentence computation means for you

If you are the person inside: read the sentence monitoring data

Ask for your sentence monitoring computation data and read the three dates on it: parole eligibility, the 180-day date, and the statutory release date. Then check the good-time figure against the table above using the length of the sentence the judgment imposed. If the aggregate sentence is ten years or more and the printout shows anything other than ten days per month of statutory good time, something is wrong — and the sentence monitoring computation sheet is the document that shows where.

Extra good time is the piece you can actually affect while inside. Industrial and camp assignments accrue it automatically; meritorious good time requires your work supervisor to write a recommendation. Twelve months of continuous earning status raises the rate from three days to five. If you have been in an earning assignment and no EGT appears on the computation, the missing document is usually a BP-390, Extra Good Time Recommendation, or an FPI-96 industrial action report that was never sent to the records office.

If you are the family: the number you want is the offense date

The number you want is not “his release date.” It is the offense date on the judgment, because that one fact decides which of two entirely different systems governs — and there is no way to answer anything else without it. If the offense predates 1 November 1987, this manual governs; if not, good conduct time under 18 U.S.C. § 3624(b) does, and the answers are different in kind, not just in degree.

Old-law cases are now, by arithmetic, at least thirty-nine years old. That means the people still serving them are almost all serving very long or life sentences, are elderly, and are before the U.S. Parole Commission rather than a court for release decisions. Two things follow. First, the Parole Commission still exists and still has jurisdiction: Congress provided on 3 February 2026 that any expiration date under section 235(b) of the Sentencing Reform Act, as it relates to chapter 311 of title 18 and the United States Parole Commission, “shall not apply during the period beginning on October 1, 2025, and ending on January 30, 2031”. Second, for many old-law prisoners the realistic paths are the Parole Commission, compassionate release, and commutation — not a recalculation.

If you are counsel: old-law sentence computation

Three audit points repay the time. One: confirm the SGT rate is set on the aggregate, not on individual counts. Section 4161 provides that “When two or more consecutive sentences are to be served, the aggregate of the several sentences shall be the basis upon which the deduction shall be computed,” and the Bureau extends that reading to concurrent sentences whose expiration extends past the anchor sentence (PS 5880.33 at p. 89). A rate computed count-by-count instead of on the aggregate can cost hundreds of days.

Two: check whether presentence credit was applied under the correct statute. Old-law jail credit runs under repealed 18 U.S.C. § 3568, not 18 U.S.C. § 3585(b), and the manual’s “in custody” definition expressly excludes time held by immigration authorities solely for a pending deportation hearing and time that would count as custody only for habeas jurisdiction purposes (PS 5880.30 at p. 46). Our page on prior custody credit covers the modern rule; the old-law rule is not the same one.

Three: on mixed U.S. Code and D.C. Code sentences, check the parole eligibility aggregation. Under the rule the Bureau built from Chatman-Bey v. Meese, 797 F.2d 987 (D.C. Cir. 1986), “the period of parole ineligibility for a U.S. Code sentence may never be used to increase the total period of parole ineligibility beyond ten years for an aggregate of U.S. Code and D.C. Code sentences” — except that where the D.C. minimum term alone exceeds ten years, the D.C. minimum controls and no part of the federal ineligibility period is added (PS 5880.30 at pp. 85–87). The manual works nine examples. They are worth reading before conceding an eligibility date.

What has not changed in PS 5880.30

PS 5880.30 is one of the oldest documents in the Bureau’s live policy set, and its history is itself the story of old law winding down.

The base Program Statement is dated July 16, 1993, signed by Director Kathleen M. Hawk. It replaced P.S. 5880.20, the original Sentence Computation Manual issued 25 September 1972, and folded in eight separate directives that had accumulated around it: P.S. 1330.8 (Rule 35 sentence correction), P.S. 5050.9 (Parole Commission Reorganization Act of 1976), P.S. 5050.34 (Canal Zone offenders), P.S. 5880.17 (statutory good time rate for violator terms), P.S. 5880.18 (YCA terms under six years), P.S. 5880.20, P.S. 5880.24 (jail time credit under § 3568), P.S. 5881.20 (extra good time), and O.M. 309-92 (foreign treaty computations) (PS 5880.30 at pp. 7–8). The stated reason was that “the repeal and supercession of numerous sections of the United States Code have caused many of that Manual’s sentence implementation instructions to become outdated.”

Four Change Notices followed, and each is filed in front of the manual in the published PDF:

Change Notice	Date	What it did
CN-01	March 10, 1994	Rescinded P.S. 1330.04 and incorporated vacated-sentence/resentencing procedures as Chapter XVI
CN-02	July 18, 1994	Rescinded O.M. 269-93; rewrote presentence-credit instructions; added the D.C./U.S. Code parole-eligibility aggregation rule from Chatman-Bey
CN-03	June 30, 1997	Added ISM procedures for forfeiture, withholding and restoration of statutory good time; explained Reno v. Koray; rewrote the Kayfez v. Gasele credit instructions; added extensive extra-good-time procedures
CN-04	September 8, 1999	Rewrote Chapter VII, pages 15–16F to implement United States v. Gonzales, 520 U.S. 1 (1997) — which held that § 924(c) “forbids a federal district court to direct that a term of imprisonment under that statute run concurrently with any other term of imprisonment, whether state or federal” — and amended aggregation practice for § 924/non-§ 924 counts

Compiled from Program Statement 5880.30 at pp. 1–6.

Nothing has changed since 1999. The Bureau’s mass reissue of 23 Program Statements effective 22 June 2026 did not touch 5880.30, and it was not among the 24 statements retired in that reissue. That stability is not an accident: the population it governs is closed and shrinking, and the underlying statutes cannot be amended because they no longer exist prospectively. What has changed, repeatedly, is the life of the Parole Commission that decides these cases — extended by Congress in 1990, 2018, 2020, 2022, 2023, 2024, and most recently on 3 February 2026, when Pub. L. 119-75 § 5011 suspended any expiration date through 30 January 2031.

Applied Insight — Christopher Zoukis, JD, MBA, Managing Director: On an old-law file the first thing we ask for is not the computation printout — it is the judgment and commitment order and every Notice of Action the Parole Commission has issued. The printout tells you what the Bureau believes; the J&C and the Notices of Action tell you what the court and the Commission actually ordered. Nearly every computation dispute we have seen on a pre-1987 sentence traces back to a mismatch between those two sets of documents, not to arithmetic.

Where people get stuck confusing parole eligibility with release

The parole eligibility date and the statutory release date get confused. These are different dates produced by different rules, and good time moves only one of them. Statutory and extra good time come off the expiration full term date to produce the statutory release date. They do not advance parole eligibility, and they do not advance the two-thirds/thirty-year mandatory parole date under § 4206(d). If the complaint is “my good time isn’t being applied to my parole date,” the answer is that under this policy it never was. Route: this is a computation question first. Ask the records office for the sentence computation data and the good time record (BP-380) through an Inmate Request to Staff, then use the administrative remedy program if the response is wrong.

Extra good time is missing because paperwork never moved. EGT depends on documents flowing from a work supervisor or industries to the records office — a BP-390 recommendation, or an FPI-96 industrial action report. When a person transfers institutions, meritorious good time terminates on arrival unless the receiving institution’s Unit Team affirmatively continues it, and the manual directs staff to note that decision in the Team Comments section of the Program Review Report (PS 5880.30 at p. 188). If no note exists and no EGT is accruing, that is the gap. Route: cop-out to the Unit Manager asking for the Program Review Report entry, then a BP-8 informal resolution, then a BP-9 to the Warden within 20 calendar days of the event, then a BP-10 to the Regional Director within 20 calendar days of the Warden’s signature and a BP-11 to General Counsel within 30 calendar days of the Regional Director’s signature.

A disciplinary forfeiture is applied without a BP-389 in the file. Statutory good time can be forfeited under repealed § 4165 and withheld for the month of the offense, but the Bureau’s own policy requires the Discipline Hearing Officer to complete a BP-389, Statutory Good Time Action Notice and place the original in the judgment and commitment file to substantiate each action (PS 5880.30 at p. 37). Extra good time, by contrast, cannot be forfeited or withheld at all — only disallowed for a single month or terminated going forward. A “forfeiture” of EGT is a category error. Route: request the BP-389 and the DHO report, then administrative remedy; if a disciplinary conviction is itself defective, challenge that first through the discipline appeal route.

A mixed old-law and Sentencing Reform Act case is aggregated when it cannot be. The Bureau decided at the November 1, 1987 changeover that old-law and SRA sentences cannot be aggregated, and that neither can be aggregated with D.C. Code sentences for offenses committed on or after 11 April 1987 (PS 5880.33 at pp. 10, 89–90). Each has to be computed standing alone. An aggregation that should not exist can produce a wrong good-time rate on both sentences at once. Route: this one usually needs counsel and, if administrative remedies fail, a petition under 28 U.S.C. § 2241 in the district of confinement — the correct vehicle for challenging the execution of a sentence rather than the sentence itself.

Related BOP policy on old-law sentence computation

• Sentence Computation Manual — CCCA (PS 5880.28) — the manual for offenses committed on or after 1 November 1987. If the offense date is after the line, that is your page, not this one.
• D.C. Code Sentence Computation (PS 5880.33) — how the Bureau computes D.C. Code sentences, including the pre-April-1987 sentences that borrow §§ 4161–4166 from this manual.
• Educational Good Time for D.C. Code Offenders (PS 5885.01) — the separate D.C. education credit, which has no old-law federal analogue.
• Good Conduct Time and good conduct time for families — the modern 54-days-per-year system that replaced statutory and extra good time.
• Prior Custody Credit — jail credit under the current statute; the old-law rule under repealed § 3568 differs.
• Nunc Pro Tunc State Designation and designation of a state institution for service of a federal sentence — where a state sentence overlaps a federal one.
• Inmate Central File, Privacy Folder and Parole Mini-Files (PS 5800.17) — the parole mini-file is where Notices of Action live.
• Release Before a Weekend or Holiday — the discretionary early-release-to-Friday rule under 18 U.S.C. § 4163 and 28 C.F.R. § 571.30.
• Challenging a BOP Sentence Computation and federal early release — what to do once you have identified the error.
• What families should know about federal prison — orientation for a first-time caller.

Frequently Asked Questions About Old Law Sentence Computation

Reviewed for legal accuracy by Elizabeth Franklin-Best, Esq., Principal Attorney·September 2026