Reno v. Koray

Summary

Chief Justice Rehnquist's opinion, joined by Justices O'Connor, Scalia, Kennedy, Souter, Thomas, Ginsburg, and Breyer, held that confinement in a community treatment center as a condition of release on bail is not “official detention” qualifying for sentence credit under 18 U.S.C. § 3585(b). The statutory context distinguishes release on bail from detention in the Attorney General's custody, regardless of how restrictive the release conditions are. The Court also afforded some deference to the Bureau of Prisons' interpretation and rejected application of the rule of lenity. It reversed and remanded. Justice Ginsburg concurred separately to note that the decision did not foreclose a due process requirement of notice and understanding that halfway-house confinement would not earn sentence credit. Justice Stevens dissented without joiners, reasoning that court-ordered, round-the-clock confinement in a jail-type facility constitutes official detention under the statute's text and purpose and would have affirmed.