LOCATION: US District Court for the Eastern District of Pennsylvania
DOCKET NO.: 98-1696
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit
CITATION: 529 US 53 (2000)
ARGUED: Dec 08, 1999
DECIDED: Mar 01, 2000
Barbara B. McDowell - Department of Justice, argued the cause for the petitioner
Kevin M. Schad - Argued the cause for the respondent
Facts of the case
Roy Lee Johnson had been serving time in federal prison for multiple drug and firearms felonies when two of his convictions were declared invalid. The District Court ordered his immediate release. Johnson's 3-year term of supervised release that was yet to be served on the remaining convictions then went into effect. As a result of serving time for the two invalid convictions, Johnson had served 2.5 years' too much prison time. After his release, Johnson filed a motion to credit the excess two and one-half years he was erroneously incarcerated toward his three-year supervised release sentence. The District Court denied relief, explaining that the supervised release commenced upon Johnson's actual release from incarceration, not before. In reversing, the Court of Appeals accepted Johnson's argument that his supervised release term commenced not on the day he left prison, but when his lawful term of imprisonment expired.
May a federal criminal defendant's excess prison time be credited towards this supervised release term, reducing its length?
Media for United States v. JohnsonAudio Transcription for Oral Argument - December 08, 1999 in United States v. Johnson
Audio Transcription for Opinion Announcement - March 01, 2000 in United States v. Johnson
William H. Rehnquist:
The opinion of the Court in No. 98-1696, United States against Johnson will be announced by Justice Kennedy.
Anthony M. Kennedy:
In order to give sentencing judges more flexibility and discretion in the federal criminal system, Congress allows sentencing courts and sometimes directs sentencing courts to impose a term of supervised release.
As a general rule, that supervised release term begins when the convicted person is released from the prison, and supervised release is intended to assist individuals in their transition to community life.
In the case before us for example, the District Court ordered that after the respondent's prison term ended, he was to serve a three-year term of supervised release on account of certain drug possession offenses.
The respondent was required among other conditions to avoid transporting firearms and to participate in a drug dependency program while he was on the supervised release.
Now in some cases, though fortunately not often, it turns out that a prisoner has served too much time in prison, too much time in actual custody.
That occurred in this case when some, but not all of the respondent's convictions were invalidated.
When the convictions were set aside, it was determined that the respondent at once should be released from incarceration and he was.
The question then became what if anything to do about the length of the term of the supervised release?
Supervised release arguably was still applicable, because there were some convictions that were not set aside to prevail.
Respondent argued that he should receive credit for the extra time served in prison on the invalid convictions thus reducing the length of the supervised release term.
The Courts of Appeals are divided on the issue and in the instant case the United States Court Appeals for the Sixth Circuit, agreed with the offender and ordered that the supervised release term be reduced by the amount of the extra prison time served.
We now reverse, the controlling statute directs that the term of supervised release does not commence until an individual is released from imprisonment.
Consistent with the statute text, we hold there is no authority to order reduction that the respondent seeks here.
Our conclusion accords with the statute purpose.
Supervised release fulfills rehabilitated needs quite distinct from the ends served by incarceration.
Accordingly we find in the Court of Appeals erred in treating respondent's time in prison as interchangeable with the term of supervised release.
Now, there could be no doubt that equitable considerations of great weight exist when an individual is incarcerated beyond the proper expiration of his prison term
And the statutory structure pertaining to supervised release terms provides two specific means to address these concerns in large part.
On remand the respondent may pursue relief under these provisions of the statute.
The opinion of the Court is unanimous.