Mont v. United States
139 S. Ct. 1826
| SCOTUS | 2019Background
- Jason Mont was released from federal prison on March 6, 2012, and began a five‑year term of supervised release scheduled to end March 6, 2017.
- While on supervised release, Mont faced multiple state charges, was arrested on June 1, 2016, and remained in state custody awaiting disposition.
- Mont pleaded guilty in state court in October 2016; on March 21, 2017, the state court sentenced him to six years and credited roughly ten months of pretrial detention as time served.
- The federal district court later issued a warrant, held a supervised‑release revocation hearing, revoked Mont’s supervised release, and imposed 42 months to run consecutive to the state term.
- The Sixth Circuit affirmed on the ground that 18 U.S.C. §3624(e) tolled Mont’s supervised‑release term during his pretrial detention because that detention was later credited as time served.
- The Supreme Court granted certiorari to resolve a circuit split about whether pretrial detention later credited as time served is "imprisonment in connection with a conviction" that tolls supervised release under §3624(e).
Issues
| Issue | Plaintiff's Argument (Mont) | Defendant's Argument (United States) | Held |
|---|---|---|---|
| Whether pretrial detention later credited as time served is "imprisoned in connection with a conviction" under 18 U.S.C. §3624(e) so as to toll supervised release | The statute’s present tense (“is imprisoned”) requires a contemporaneous assessment; pretrial detention before conviction is not imprisonment "in connection with a conviction" and therefore does not toll | The phrase "imprisoned in connection with a conviction" reasonably includes pretrial detention that is later credited to a conviction; retrospective tolling is consistent with statutory text and context | Held: Yes. If pretrial detention is later credited as time served on a conviction, it qualifies as imprisonment "in connection with a conviction" and tolls supervised release under §3624(e) (majority). |
| Whether courts may determine tolling retrospectively after conviction/credit calculation | Mont: Present‑tense wording forbids backward‑looking tolling; courts should assess tolling contemporaneously | U.S.: The 30‑day exception and common practice of crediting pretrial time require a retrospective calculation once conviction/credit is known | Held: Courts may make the tolling calculation after the fact (e.g., upon sentencing or release); the statute contemplates such retrospective assessment (majority). |
| Whether tolling conflicts with statutory design (double‑counting / purpose of supervised release) | Mont: Allowing tolling based on later credit creates uncertainty and may improperly give defendants a windfall or deprive notice; revocation power can be preserved via §3583(i) summons/warrant | U.S.: Tolling aligns with sentencing statutes that credit pretrial detention and preserves distinct roles of imprisonment and supervised release without producing unfair windfalls | Held: Majority rejects windfall concern; tolling prevents giving defendants credit on both sentences for the same detention and accords with statutory scheme. |
Key Cases Cited
- United States v. Johnson, 529 U.S. 53 (2000) (distinguishing supervised release from imprisonment and explaining supervised release’s postconfinement monitoring purpose)
- Merrill Lynch, Pierce, Fenner & Smith Inc. v. Dabit, 547 U.S. 71 (2006) ("in connection with" can bear a broad interpretation)
- Maracich v. Spears, 570 U.S. 48 (2013) (observing that "in connection with" is indeterminate in scope)
- Tapia v. United States, 564 U.S. 319 (2011) (discussing "imprisonment" as a prison term in sentencing context)
- Barber v. Thomas, 560 U.S. 474 (2010) (treating "term of imprisonment" as the sentence imposed or time actually served)
- Argersinger v. Hamlin, 407 U.S. 25 (1972) (noting right to counsel before imprisonment for an offense)
- United States v. American Union Transport, Inc., 327 U.S. 437 (1946) (describing "in connection with" as broad and general)