US v. Ide, 09-4833, concerned a challenge to the district court's grant of government's petition to revoke defendant's term of supervised release originally imposed in May 2002 as part of his sentence on a federal charge, claiming that defendant's commission of an additional state offense, along with his failure to file monthly reports, violated the conditions of his supervised release. In affirming, the court held that, under the circumstances, a defendant's supervised release term is tolled under 18 U.S.C. section 3624(e) during the period that he spent in pretrial detention awaiting trial on the state charge for which he later was convicted.
In holding that section 3624(e) is unambiguous and that it plainly provides for tolling the term of supervised release under the circumstances, the court wrote: "We observe that Congress included the phrase "during any period" in the same sentence as the phrase "imprisoned in connection with a conviction." The phrase "during any period" necessarily includes all time periods, both before and after a conviction, for which an imprisonment is connected with that conviction."
- Read the Fourth Circuit's Full Decision in US v. Ide, 09-4833