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Mont v. United States

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Supreme Court of the United States
Mont v. United States
Term: 2018
Important Dates
Argument: February 26, 2019
Decided: June 3, 2019
Outcome
Affirmed
Vote
5-4
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Samuel Alito • Brett Kavanaugh
Dissenting
Sonia Sotomayor • Stephen Breyer • Elena Kagan • Neil Gorsuch


Mont v. United States is a case argued before the Supreme Court of the United States on February 26, 2019, during the court's 2018-2019 term. The case concerned supervised release for criminals.

On June 3, 2019, the court affirmed the ruling of the United States Court of Appeals for the 6th Circuit. The court held Mont's supervised release was tolled under 18 U.S.C. §3624(e), which says a "term of supervised release does not run during any period in which the person is imprisoned in connection with a conviction for a . . . crime unless the imprisonment is for a period of less than 30 consecutive days."[1] Click here for more information.

The case came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit.[2]

HIGHLIGHTS
  • The case: In 2005, Jason Mont was convicted on federal drug charges and sentenced to 120 months in prison and five years of supervised release. In 2017, Mont was sentenced for committing state-level crimes. The federal district court then decided whether he violated the terms of his supervised release and sentenced Mont to 42 months in prison to be served consecutively with his imprisonment for state-court convictions.
  • The issue: Whether a statute directed to the administration of imprisoned individuals serves as authority to alter or suspend the running of a criminal sentence of supervised release, when such 'tolling' is without judicial action, and requires the term 'imprisonment' as used in the administrative statute, to include pretrial detention prior to an adjudication of guilt. Is a district court required to exercise its jurisdiction in order to suspend the running of a supervised release sentence as directed under 18 U.S.C. §3583(i) prior to expiration of the term of supervised release, when a supervised release is in pretrial detention, or does 18 U.S.C. §3624(e) toll the running of supervised release while in pretrial detention?[3]
  • The outcome: On June 3, 2019, the court affirmed the ruling of the United States Court of Appeals for the 6th Circuit, holding Mont's supervised release was tolled under 18 U.S.C. §3624(e), which says a "term of supervised release does not run during any period in which the person is imprisoned in connection with a conviction for a . . . crime unless the imprisonment is for a period of less than 30 consecutive days."[1]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 3, 2019: U.S. Supreme Court affirmed the 6th Circuit Court's ruling.
    • February 26, 2019: Oral argument
    • November 2, 2018: U.S. Supreme Court agreed to hear case
    • May 15, 2018: Petition filed with U.S. Supreme Court
    • February 9, 2018: 6th Circuit affirmed the lower court's ruling.

    Background

    In 2005, Jason Mont was convicted on federal drug charges and sentenced to 120 months in prison and five years of supervised release. In 2016, while on supervised release, Mont pleaded guilty to committing state-level offenses. He was then sentenced on March 21, 2017, and the judge "credited as time served the roughly ten months Mont had spent incarcerated pending a disposition. On March 30, 2017, Mont’s probation officer informed the federal district court of Mont’s state-court convictions and sentences, and the court exercised jurisdiction to adjudicate whether he violated the terms of his supervised release. The district court then sentenced Mont to 42 months’ imprisonment, to be served consecutively with his imprisonment for state-court convictions," according to Oyez.[5]

    Mont argued that "the district court lacked jurisdiction to impose the revocation because his term of supervised release had already expired. Because binding precedent instead makes clear that Mont’s term of supervised release was paused by his imprisonment in connection with a new state conviction," according to the Second Circuit Court. The court affirmed the ruling of the district court.[4]

    Mont appealed to the Supreme Court, and the court agreed to hear the case on November 2, 2018.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Whether a statute directed to the administration of imprisoned individuals serves as authority to alter or suspend the running of a criminal sentence of supervised release, when such 'tolling' is without judicial action, and requires the term 'imprisonment' as used in the administrative statute, to include pretrial detention prior to an adjudication of guilt. Is a district court required to exercise its jurisdiction in order to suspend the running of a supervised release sentence as directed under 18 U.S.C. §3583(i) prior to expiration of the term of supervised release, when a supervised releasee is in pretrial detention, or does 18 U.S.C. §3624(e) toll the running of supervised release while in pretrial detention?

    Outcome

    On June 3, 2019, the court affirmed the ruling of the United States Court of Appeals for the 6th Circuit, holding Mont's supervised release was tolled under 18 U.S.C. §3624(e), which says a "term of supervised release does not run during any period in which the person is imprisoned in connection with a conviction for a . . . crime unless the imprisonment is for a period of less than 30 consecutive days."[1]

    Justice Clarence Thomas delivered the opinion of the court, joined by Chief Justice John Roberts and Justices Ruth Bader Ginsburg, Samuel Alito, and Brett Kavanaugh. Justice Sonia Sotomayor dissented, joined by Justices Stephen Breyer, Elena Kagan, and Neil Gorsuch.[1]

    Opinion

    In his opinion, Justice Thomas wrote:[1]

    “ This case requires the Court to decide whether a convicted criminal’s period of supervised release is tolled—in effect, paused—during his pretrial detention for a new criminal offense. ... Given the text and statutory context of §3624(e), we conclude that if the court’s later imposed sentence credits the period of pretrial detention as time served for the new offense, then the pretrial detention also tolls the supervised-release period. [6] ”

    Dissenting opinion

    Justice Sotomayor filed a dissenting opinion, joined by Justices Breyer, Kagan, and Gorsuch.[1]

    In her dissent, Sotomayor wrote:[1]

    “ A term of supervised release is tolled when an offender "is imprisoned in connection with a conviction." 18 U. S. C. §3624(e). The question before the Court is whether pretrial detention later credited as time served for a new offense has this tolling effect. The Court concludes that it does, but it reaches that result by adopting a backward-looking approach at odds with the statute’s language and by reading the terms "imprisoned" and "in connection with" in unnatural isolation. Because I cannot agree that a person "is imprisoned in connection with a conviction" before any conviction has occurred, I respectfully dissent. [6] ”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    Click here to read a transcript of the oral arguments.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, Mont v. United States, decided June 3, 2019
    2. ↑ Supreme Court of the United States, "17-8995 Mont v. United States," accessed February 3, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-8995 Mont v. United States," accessed February 3, 2019
    4. ↑ 4.0 4.1 SCOTUSblog, "Mont v. United States," accessed February 3, 2019
    5. ↑ Oyez, "Mont v. United States," accessed February 4, 2019
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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