holding that, while an inmate confined in a community treatment center after having been "detained" and committed to the BOP's custody, and an inmate "released" to such a center on bail were similarly situated, in fact, their relative positions were legally distinct because the former remained subject to BOP control, and thus was eligible for a credit under 18 U.S.C. § 3585(b)
How later courts described this case
- holding that, while an inmate confined in a community treatment center after having been "detained" and committed to the BOP's custody, and an inmate "released" to such a center on bail were similarly situated, in fact, their relative positions were legally distinct because the former remained subject to BOP control, and thus was eligible for a credit under 18 U.S.C. § 3585(b)
- recognizing that time spent in community confinement subject to BOP custody entitles a prisoner to sentencing credit, while community confinement on pretrial release does not, because “[ujnlike defendants ‘released’ on bail, defendants who are ‘detained’ or sentenced’ always remain subject to the control of the Bureau ”
- recognizing that the relevant criteria for determining whether a court-imposed period of pre-trial detention in a CCC or other facility may be credited against a term of imprisonment is not the type or place of confinement but whether the defendant is in BOP custody
- holding that 18 U.S.C. § 3585(b) must be construed in conjunction with the Bail Reform Act because “the Bail Reform Act of 1984 was enacted in the same statute as the Sentencing Reform Act of 1984, of which § 3585 is a part”
Written by the judges who cited it.
Distinguished
Distinguished by O'Dell v. Barron, 79 F. App'x 181 (2003)
O’Dell contends on appeal that Reno is inapposite because unlike that defendant, who sought sentence credit for time spent in “jail-type confinement” in a treatment facility while he was a pretrial detainee, O’Dell began to serve his sentence and then was released on supervised release.
The opinion
Justice Ginsburg,
concurring.
As the Government reads 18 U. S. C. § 3585 (b), Koray gains credit against his sentence for the two months he spent in jail, but not for the five months’ close confinement he encountered at the halfway house. The Court cogently explains why it adopts the Government’s interpretation. I write separately to point out that Koray has not argued before us that he did not elect bail intelligently, i. e., with comprehension that time in the halfway house, unlike time in jail, would yield no credit against his eventual sentence. The Court thus does not foreclose the possibility that the fundamental fairness we describe as “due process” calls for notice and a comprehension check. Cf. Fed. Rule Crim. Proc. 11 (setting out information a court is to convey to assure that a defendant who pleads guilty understands the consequences of the plea).