OCTOBER TERM, 1994
certiorari to the united states court of appeals for the third circuit
No. 94-790. Argued April 24, 1995—Decided June 5, 1995
Under 18 U. S. C. § 3585(b), a defendant generally must "be given credit toward the service of a term of imprisonment for any time he has spent in official detention prior to the date the sentence commences." Before respondent's federal sentence commenced, he was "released" on bail pursuant to the Bail Reform Act of 1984 and ordered confined to a community treatment center. After his prison sentence began, the Bureau of Prisons (BOP) relied on its established policy in refusing to credit toward his sentence the time he had spent at the treatment center. He exhausted his administrative remedies and then filed a federal habeas corpus petition. A District Court denied his petition on the ground that his stay at the center was not "official detention" under § 3585(b). In reversing, the Court of Appeals declined to defer to BOP's view that time spent under highly restrictive conditions while "released" on bail is not "official detention" because a "released" defendant is not subject to BOP's control. It reasoned instead that "official detention" includes time spent under conditions of "jail-type confinement."
Held: The time respondent spent at the treatment center while "released" on bail was not "official detention" within the meaning of § 3585(b). Pp. 55-65. (a) Viewed in isolation, the phrase "official detention" could either refer, as the Government contends, to a court order detaining a defendant and committing him to the custody of the Attorney General for confinement, or, as respondent argues, to the restrictive conditions of his release on bail under an "official" order that significantly curtailed his liberty. Examination of the phrase in light of the context in which it is used, however, reveals that the Government's interpretation is correct. P. 56. (b) The "official detention" language must be construed in conjunction with the Bail Reform Act of 1984, since § 3585(b) provides credit only for presentence restraints on liberty and since it is the Bail Reform Act that authorizes federal courts to place such restraints on a defendant's liberty. That Act provides a court with only two choices: It may either "release" a defendant on bail, 18 U. S. C. § 3142(c), or order him "detained" without bail, § 3142(e). A defendant suffers "detention" only when committed to the Attorney General's custody, § 3142(i)(2); a de-Page: Index 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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