Malik Ferguson v. United States, 157 A.3d 1282

In 2014 Malik Ferguson, a youth offender under the Youth Rehabilitation Act (YRA), was convicted of two misdemeanors and sentenced to 30 days on each count; execution was suspended and he was placed on 12 months' supervised probation.
After alleged probation violations and a subsequent arrest on a new misdemeanor (later dismissed), the trial court revoked probation in March 2015 and resentenced Ferguson to concurrent 30-day jail terms, with credit for time already served.
Ferguson moved to set aside his convictions under the YRA; the trial court denied the motion, concluding that D.C. Code § 24-906(b) gives the United States Parole Commission (USPC) exclusive jurisdiction to grant a post-sentence set aside when a sentence expires before unconditional discharge.
Ferguson appealed the jurisdictional ruling; the government argued that § 24-906(b) and 28 C.F.R. § 2.208 vest authority in the USPC, while Ferguson argued the statute is silent as to misdemeanants and the Superior Court retains authority under § 24-906(e).
The D.C. Court of Appeals reviewed the statutory and regulatory scheme holistically, focusing on the felony/misdemeanor and commitment/probation distinctions in Chapter 9 of Title 24 and related USPC regulations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Superior Court or the USPC has authority to decide a discretionary post‑sentence set aside of misdemeanor convictions for a youth offender whose probation was revoked and who served a short jail term	Ferguson: § 24‑906(e) vests the Superior Court with discretion over youth misdemeanants placed on probation (court may set aside convictions)	Government: § 24‑906(b) and 28 C.F.R. § 2.208 give the USPC authority (and effectively sole jurisdiction) when a sentence expires before unconditional discharge	The Superior Court has jurisdiction to decide Ferguson’s motion; the USPC does not have sole authority to grant or deny a discretionary set aside for youthful misdemeanants in these circumstances; vacated and remanded to the trial court

Holloway v. United States, 951 A.2d 59 (D.C. 2008) (discussing YRA purposes and treatment of youthful offenders)
W.H. v. D.W., 78 A.3d 327 (D.C. 2013) (statutory interpretation is a holistic endeavor)
Thomas Jefferson Univ. v. Shalala, 512 U.S. 504 (1994) (statutory context clarifies ambiguous provisions)
United Savings Ass’n of Texas v. Timbers of Inwood Forest Assocs., Ltd., 484 U.S. 365 (statutory language must be read with entire scheme)
Abadie v. District of Columbia Contract Appeals Bd., 843 A.2d 738 (D.C. 2004) (related statutes should be considered together)
Hunt v. United States, 109 A.3d 620 (D.C. 2014) (discussing USPC authority under D.C. Code § 24‑131 and 28 C.F.R. § 2.70)