United States v. Freeman, No. 23-6394 (2d Cir. 2024)
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Rodger Freeman, convicted of a felony in the United States District Court for the Eastern District of New York, was sentenced to imprisonment followed by a term of supervised release. After completing his federal prison sentence, Freeman was transferred to New York State custody to face a pending indictment. The New York Appellate Division vacated Freeman’s state convictions due to procedural error and ordered a new trial. Freeman was held in state custody for over four years pending retrial. The state eventually dismissed the charges against Freeman and released him from pre-trial detention.
The District Court held that Freeman's term of supervised release began only after his release from state custody, not upon his release from federal custody. The court based its decision on United States v. Johnson, which established that a term of federal supervised release does not begin until a defendant’s imprisonment has ended.
The United States Court of Appeals for the Second Circuit affirmed the District Court's decision. The Court of Appeals agreed with the lower court's interpretation of 18 U.S.C. § 3624(e), which states that a term of supervised release commences on the day the person is released from imprisonment. The court held that Freeman's term of supervised release began on the day he was released from state custody, not federal custody. The court did not address the question of whether Freeman’s federal term of supervised release was “tolled” during his years in state custody following the vacatur of his state convictions.
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