Foster v. Wainwright, 820 F. Supp. 2d 36

Foster pled guilty in DC Superior Court to one count of robbery, receiving a three-year prison term with part suspended and three years probation.
probation was revoked in 2005, resulting in imposition of the three-year prison term followed by a three-year supervised release term.
Credit for time served and good time reduced his release date to November 14, 2006, after which he began supervised release.
During supervised release, Foster was subjected to drug testing and abstinence conditions; USPC later charged violations in 2009 for marijuana use, missed drug tests, and GPS curfew noncompliance.
An expedited revocation was agreed, yielding a 10-month imprisonment followed by 26 months of supervised release; release began January 19, 2010.
In 2011, Foster faced additional charges (three testing failures and a vehicle/license offense) leading to further detention and a 150-day state sentence; USPC issued a 2011 violator warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioner’s custody violated law after supervised release?	Foster argues he completed both prison and supervised release.	USPC retained authority during supervised release and could impose further imprisonment for violations.	USPC authority persisted; no unlawful custody.
Whether the sentence and revocation complied with DC law and the split-sentence framework?	Time spent on supervised release should count toward the sentence‑term computation.	Probation time is forfeited on revocation; sentence exceeds initial term as authorized by DC law.	Record shows lawful computation and forfeiture of probation time upon revocation.
Whether habeas relief is proper under 28 U.S.C. § 2241?	Custody is unlawful because the term has expired.	USPC remained authorized; the longer supervisory regime continued.	Petition denied; custody not unlawful.

Richardson v. United States, 927 A.2d 1137 (D.C. 2007) (split sentence and probation concepts under DC law)