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Ninth Circuit: “Supervised Release” is Not “Imprisonment”
Loaded on May 15, 2009
published in Prison Legal News
May, 2009, page 44
The Ninth Circuit U.S. Court of Appeals has held that with respect to 18 U.S.C. § 3624(e), being on supervised release in a state community pre-release center did not toll a state prisoner’s concurrent federal supervised release. Since the plaintiff had therefore served all of his federal probation period while …
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- Sexual Abuse by Prison and Jail Staff Proves Persistent, Pandemic, by Gary Hunter
- From the Editor, by Paul Wright
- Billionaire-Funded California Voter Initiative Triples Lifer Parole Denial Intervals, Imposes Restrictions on Parole Violators
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- Caging Kids for Cash: Two Pennsylvania Judges Guilty of Selling Out Juvenile Justice System, by Matthew Clarke
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- Conditions in Maricopa County, Arizona Jails Still Unconstitutional, by Matthew Clarke
- Hawai’i Supreme Court Holds Takings Clause Requires Payment of Interest on Prisoner Trust Accounts, by David Reutter
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More from these topics:
- Sixth Circuit Announces State-Law Exceptions to Appeal Deadlines Preserve “Pending” Status Under AEDPA, Holding Belated-Appeal Procedures Toll Federal Habeas Limitations Period, April 1, 2026. Limitations, Habeas Corpus, AEDPA, Appealable Issues/Orders, Failure to Address/Advise Defendant.
- One in 10 Prison Admissions Is Now for Technical Parole Violation, March 1, 2026. Parole Conditions, State Legislation, Restrictions, discrimination, Revocation Proceedings.
- Eleventh Circuit Upholds Dismissal of Six Female Alabama Jail Detainees’ Sexual Assault Suit, Jan. 1, 2026. Jail Misconduct, Summary Judgment, Limitations, Municipal Liability, Criminal Sexual Abuse.
- Wisconsin DOC Is Not Tracking Work Release Data, Jan. 1, 2026. Work Release, Prison Labor, Statistics/Trends, Fair Labor Standards Act.
- Ninth Circuit Grants Equitable Tolling Under AEDPA Where Attorney Abandoned Prisoner by Failing to Communicate for Nine Months and Prison Officials Delayed Processing Filing Documents, Dec. 15, 2025. Attorney Misconduct, Legal Materials, Law Library Access/Adequacy, Limitations, AEDPA.
- Hyundai and Kia Sued in California for Use of Prison Labor in Southern States, Dec. 1, 2025. Work Release, Prison Labor, Work Conditions/Safety, Fair Labor Standards Act (FLSA).
- First Circuit: District Court Abused Discretion by Sua Sponte Raising Statute of Limitations Defense to Habeas Petition After Respondents Had Intelligently “Waived” It by Being Aware of Availability but Failing to Assert It, Nov. 15, 2025. Defenses, Limitations, Habeas Corpus, Double jeopardy, Knowingly and Intelligently.
- Eighth Circuit Announces § 2255 One-Year Limitations Period Begins to Run in Deferred-Restitution Criminal Case When Subsequent Amended Judgment Finalizes Amount, Nov. 15, 2025. Limitations, Habeas Corpus, Restitution, AEDPA.
- California Approves Higher Wage for Prisoner Firefighters (But Still Underpays), Nov. 1, 2025. Work Release, Prison Labor, Injury -- Misc., Rehabilitation/Recidivism, Good Time.
- Appeals Court Rules Michigan’s Tolling Provision Is Not Inconsistent with the PLRA, Nov. 1, 2025. Administrative Exhaustion (PLRA), Limitations, 42 U.S. Code § 1983, civil action for deprivation of rights, Tolling of Statutes of Limitations and Laches.

