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Eighth Circuit Affirms Denial of Credit for Time Served in Halfway House
Mar 22nd, 2014

In United States v. Parris, issued on February 4, 2014 (published), the Court affirmed the district court’s refusal to grant Parris credit for time served at a half-way house prior to her sentencing. Parris’ time in the half-way house was designated “a period of release” in her presentence report, and was therefore not detention in a “‘penal or correctional facility’ . . . subject to [the Bureau of Prison]’s control.” (The Court did not address — and perhaps the issue was not raised — whether the sentencing court can take account of the more restrictive conditions of pre-trial release in crafting the appropriate sentence under 18 USC  § 3553(a)) .



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JaneAnne Murray is a criminal defense lawyer in Minneapolis.

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