United States v. Angelo Earl, 729 F.3d 1064

Earl pled guilty to four drug offenses, including attempting to sell cocaine; sentenced January 18, 2000 to 121 months’ imprisonment and five years’ supervised release.
Supervised release commenced June 10, 2007; BOP placed him first in a halfway house, then in home confinement.
On February 9, 2012, probation filed a petition to revoke two conditions of release.
February 28, 2012 revocation hearing held; Earl admitted violating one condition (associating with known felons).
District court sentenced six months’ imprisonment and two years’ additional supervised release; BOP released Earl August 25, 2012.
Issue presented: whether the district court retained jurisdiction to revoke Earl’s supervised release given he was on home confinement; court held it did retain jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether home confinement begins the term of supervised release	Earl argues home confinement starts supervised release.	Miller/Johnson framework holds no; release from imprisonment is required.	No; term does not begin during home confinement; court retained jurisdiction.

United States v. Johnson, 529 U.S. 53 (2000) (supervised release begins after imprisonment; requires actual release from BOP custody)
United States v. Miller, 547 F.3d 1207 (2008) (remains in BOP custody during work-release; supervised release does not begin until imprisonment ends)
United States v. Sullivan, 504 F.3d 969 (2007) (fact-specific inquiry on confinement; pre-release center not 'imprisonment' for running of supervised release)
United States v. Turner, 689 F.3d 1117 (2012) (civil detention under Adam Walsh Act does not toll supervised release; distinction between criminal and civil custody)
United States v. Vargas-Amaya, 389 F.3d 901 (2004) (bounds of court’s jurisdiction to revoke supervised release during pendency)