×
You've used up your 3 free articles for this month. Subscribe today.
Ninth Circuit: Adam Walsh Detention Doesn’t Toll Term of Supervised Release
Loaded on Nov. 15, 2013
by Derek Gilna
published in Prison Legal News
November, 2013, page 42
In a case of first impression, the Ninth Circuit Court of Appeals held that the period of time spent in civil confinement under the Adam Walsh Act does not constitute “imprisonment,” and that a defendant’s period of supervised release is thus not tolled and continues to run during that time.
Filed under:
Sex Offenders (Discrimination),
Probation,
Federal Statutory Law,
Sex Offender Registration and Notification Act,
Civil Commitment.
Location:
California.
…
Full article and associated cases available to subscribers.
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
More from this issue:
- The Too-Many Prisoners Dilemma, by Dan Froomkin
- From the Editor, by Paul Wright
- Texas Judges Rarely Disciplined, Seldom Publicly, by Matthew Clarke
- Habeas Hints: Staring Down the Two-Headed Monster: Richter-Pinholster, by Kent A. Russell
- The Real Costs of Incarceration in the United States
- Attorney Fees Not Exempt from Disclosure Under California Public Records Act
- PLN Files Censorship Suit Against Nevada DOC
- Traumatic Brain Injury Rate High Among Prisoners, by Matthew Clarke
- Debtors' Prisons Returning to America, by David Reutter
- Hell on Earth: Sexual Victimization of the Criminally Insane, by David Rosen
- China Vows to Finance Incarceration with Public Funds, Not Prison Profits
- Oregon Considers Subsidizing Prison Medical Costs Through Medicaid
- PLN Challenges Postcard-only Policy at Tennessee Jail
- Federal Justice Grants Favor Prosecution, Law Enforcement Over Indigent Defense
- Texas Prison Population Drops but Savings Evaporate, by Matthew Clarke
- Federal Prisoners Paid During Government Shutdown, but Not Prison Guards, by Derek Gilna
- Minnesota Judge Condemns System that Jails Mentally Ill
- GEO Group Pulls out of Mississippi Prisons, by David Reutter
- Gun Found in Segregation Cell at Privately-operated Mississippi Prison
- New York City Jail Chaplain Fined for Accepting Bribe, Pleads Guilty to Fraud Charges
- New Exonerations Registry Catalogs Over 2,400 Wrongful Convictions
- New Hampshire Supreme Court Revives Prisoner's Negligence Action
- Prisoners in Texas Jail Providing Less Slave Labor
- Book Review: Against Their Will: The Secret History of Medical Experimentation on Children in Cold War America, by Christopher Zoukis
- Second Circuit: Bankruptcy Automatic Stay is No Excuse for Non-payment of Restitution, by Derek Gilna
- Third Circuit Reverses More Stringent Conditions of Supervised Release, by Derek Gilna
- Best Criminal Defense Pleading Ever!, by Alex Friedmann
- Connecticut Supreme Court Reverses FOIA Disclosure of NCIC Printout
- California: No-Gang-Contact Probation Condition Struck Down
- Ninth Circuit: Adam Walsh Detention Doesn’t Toll Term of Supervised Release, by Derek Gilna
- Four West Virginia Officials, including Circuit Court Judge, Face Federal Charges, by Christopher Zoukis
- U.S. Department of Justice Reports Statistics on State Prosecutors, by Matthew Clarke
- Eighth Circuit Upholds North Dakota Transient’s Failure-to-Register Conviction
- California: Enhanced Presentence Conduct Credits Not Available to Defendants Who Committed Crimes Before Statute’s Effective Date
- California: State Not Liable for Failure to Provide Needed Treatment so Long as Medical Care is Summoned
- Philippines Prison Suspends Thriller Dancers
- ICE Directive May Limit Solitary Confinement of Immigrant Detainees, by Derek Gilna
- Denial of Contraceptive Pill to Prisoner States Cause of Action
- Montana Jail Fresh Air/Exercise Lawsuit Certified as Class Action, Then Settles
- Anonymous PREA Hotlines Not So Anonymous
- D.C. Circuit Clears Terrorism Suspect after 11-Year Ordeal, by Derek Gilna
- Audit Reveals Federal Prison Industries Faces Declining Revenue, Job Losses, by Derek Gilna
- Fifth Circuit: No Right to RDAP for Non-citizen Federal Prisoner
- Prison Sentence Imposed for Sole Purpose of Drug Treatment Vacated by Eighth Circuit, by Derek Gilna
- Court Baffled by BOP's Steel-toe Boot Requirement for Prisoners, by Derek Gilna
- News in Brief
More from Derek Gilna:
- Federal Judge in Louisiana Issues Sweeping Opinion Finding Numerous Eighth Amendment, ADA and RA Violations at Angola, April 1, 2022
- Human Rights Defense Center Prevails in Censorship Lawsuit Against Napa County Jail, California, Sept. 1, 2021
- California State Auditor’s Report Faults Counties for Waste and Poor Oversight of State Funds Used in “Public Safety Realignment”, Sept. 1, 2021
- The Fight Over Cellphones in Prisons Rages On, Sept. 1, 2021
- District Court Extends Armstrong Order to Five Additional California Prisons, Sept. 1, 2021
- HRDC Settles Censorship Lawsuit with Johnson County, Kansas Jail for $50,000 and Policy Changes, Aug. 1, 2021
- Virginia Prosecutors to Dismiss 400 Drug Convictions Tied to Disgraced Cop, July 15, 2021
- Discredited New York Police Detective’s False Testimony Causes the Dismissal of Close to 100 Drug Convictions, June 15, 2021
- D.C. Department of Forensic Sciences Firearms Examination Unit Under Fire, April 15, 2021
- Mississippi Joins Illinois and Few Other States Prioritizing Vaccination of State Prisoners to Slow Spread of COVID-19, April 1, 2021
More from these topics:
- South Carolina Supreme Court Announces Penile Plethysmograph Results Are Inadmissible Until Underlying Science Becomes Standardized, Affirming Reversal of Sexually Violent Predator Commitment, June 1, 2026. Civil Commitment, Sexually Dangerous Persons/Sexual Violent Predators, Evidence - Integrity/Reliability of, Prejudice - Potential for Undue, Scientific Testimony or Evidence.
- Sixth Circuit Announces Federal Coercion and Enticement Statute Requires Knowledge of Victim’s Minor Status, Deepening Circuit Split, May 1, 2026. U.S. Sentencing Guidelines, Sex Offender Registration and Notification Act, Statutory Construction/Interpretation, Sentence, Miscalculation of the Guidelines Sentencing Range.
- Fifth Circuit Holds Texas Sexual Assault of a Child Statute Sweeps More Broadly Than Federal SORNA Tier Offenses, March 1, 2026. Sex Offender Registration and Notification Act, Qualifying Offenses, Plain Error, Elements of Offense, Miscalculation of the Guidelines Sentencing Range.
- Shadow Prisons: How Civil Commitment Leads to Longer Confinement, Jan. 1, 2026. Sex Offender Treatment, Involuntary Treatment/Drugging, Civil Commitment, Sexually Dangerous Persons/Sexual Violent Predators, Sex Offense Registration Act (SORNA).
- Fifth Circuit Upholds Dismissal of Suit by Civilly Committed Texan, Dec. 1, 2025. Sex Offenders (Discrimination), Conditions of Confinement, Complaints, Grievances, Civil Commitment.
- Third Circuit Announces “Commencement of the Instant Offense” in Guidelines § 4A1.2(e) Unambiguously Refers Only to Specific Offense of Conviction, Not Relevant Conduct, Nov. 15, 2025. U.S. Sentencing Guidelines, Sex Offender Registration and Notification Act, Prior Conviction/Sentence/Incarceration, Adequacy of Criminal History Category, Statutory Construction/Interpretation.
- Former Prisoners’ Challenge to Virginia Constitution’s Felony Disenfranchisement Clause Allowed to Proceed, Nov. 1, 2025. Injunctions, Federal Statutory Law, Voting Rights Act, Sovereign Immunity, Constitutional Challenges/Law, Felon Disenfranchisement Statute, Prison Regulations.
- Idaho Supreme Court Announces Warrantless Search of Civilly Committed Individual Violates Fourth Amendment, Oct. 15, 2025. Civil Commitment, Exclusionary Rule, Pat Down Searches, Scope of Permissible Searches, Suspicionless Searches.
- Florida Appeals Court Finds Rationale for “Sexual Predator” Label on Former Prisoner’s Drivers License, Oct. 1, 2025. Sex Offender Registration, Sex Offender Registration and Notification Act, Sexually Dangerous Persons/Sexual Violent Predators, Prisoners' Rights.
- First Circuit Announces What Constitutes ‘Otherwise Using’ a Dangerous Weapon for Purposes of the Four-Level Enhancement Under Guidelines § 2B3.1(a), May 15, 2025. U.S. Sentencing Guidelines, Probation, Sentence Enhancements/Departures.

