Mont v. United States

Under 18 U.S.C. § 3624(e), pretrial detention qualifies as “imprison[ment] in connection with a conviction” when subsequent sentencing credits that detention as time served, thereby tolling the period of supervised release.

Petitioner was arrested for violating the terms of his supervised release, of which the remaining period was tolled. Petitioner argued that the present tense used in the text of 18 U.S.C. § 3624(e), specifically the phrase “is imprisoned,” precludes courts from tolling supervised release periods based on pretrial detention. Petitioner challenged the district court’s jurisdiction, but the court concluded that it maintained authority under 18 U.S.C. § 3583(i), revoked his supervised release, and imposed sentencing. The Sixth Circuit affirmed on different grounds, holding that Petitioner’s supervised release period was tolled under § 3624(e). On appeal, the Supreme Court affirmed, holding that “pretrial detention later credited as time served for a new conviction is ‘imprison[ment] in connection with a conviction’ and thus tolls the supervised-release term under § 3624(e).” The Court reasoned that the text and context of “is imprisoned” encompasses pretrial detention when credited toward the new sentence following conviction, and that legislative intent supports the notion that courts must be allowed to retrospectively analyze pretrial detention to decide whether it should toll a period of supervised release. Furthermore, the Court reasoned that because § 3624(e) provided independent grounds it is immaterial whether the district court could have maintained authority under § 3583(i). Therefore Petitioner’s period of supervised release is tolled. AFFIRMED.