United States v. Ide
2010 U.S. App. LEXIS 23420
| 4th Cir. | 2010Background
- Ide pled guilty in 2002 to conspiracy to distribute heroin; district court sentenced him to 30 months' imprisonment with a three-year supervised release term to begin after release on February 11, 2004.
- Ide began serving his supervised release in 2004 but was arrested by West Virginia authorities in January 2005 on state charges for conspiracy to operate a methamphetamine laboratory, remained in custody through trial.
- A state jury convicted Ide in September 2005; he received a two-to-five year state sentence in November 2005 and was credited for 7 months 6 days of pretrial detention; he was released from state custody in July 2007 after 22 months 22 days in prison post-conviction.
- In June 2009, the government petitioned district court to revoke Ide's federal supervised release for violating conditions, including failure to file monthly reports and the state offense.
- Ide moved to dismiss, arguing the petition was untimely because his supervised release had already run for about 41 months, exceeding the 36-month term; the government argued § 3624(e) tolled the term during pretrial detention.
- The district court held the term tolled under § 3624(e), timely filed the revocation petition, and ultimately revoked Ide's supervised release, sentencing him to six months' imprisonment followed by seven months of supervised release.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 3624(e) tolls supervised release during pretrial detention | Government argues yes; detention on a state charge later convicted tolls the term. | Ide argues no; pretrial detention is not 'imprisoned in connection with a conviction' for tolling. | Yes, tolling applies; detention tolls the term. |
Key Cases Cited
- United States v. Morales-Alejo, 193 F.3d 1102 (9th Cir. 1999) (pretrial detention not tolling the term under § 3624(e))
- United States v. Goins, 516 F.3d 416 (6th Cir. 2008) (pretrial detention tolls supervised release; 'imprisoned' includes pretrial detention)
- United States v. Molina-Gaza,, 571 F.3d 470 (5th Cir. 2009) (adopts Sixth Circuit approach tolling during pretrial detention)
- United States v. Johnson, 581 F.3d 1310 (11th Cir. 2009) (pretrial detention tolled supervised release when crimenal charge later led to conviction)