Rico v. United States (tolling supervised release)
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Rico v. United States (tolling supervised release)
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The Supreme Court held that the Sentencing Reform Act does not permit courts to automatically extend a defendant’s term of supervised release when the defendant absconds, reversing the Ninth Circuit’s rule that treated time on the run as “tolled.” Isabel Rico’s supervised release had been set to expire in 2021, but after she absconded and later committed a state drug offense in 2022, the Ninth Circuit allowed the district court to treat that offense as a federal supervised‑release violation by deeming her term extended until her arrest in 2023. The Court rejected that approach, explaining that Congress provided specific mechanisms for extending, tolling, or revoking supervised release—and none authorize automatic extension for abscondment, which risks exceeding statutory maximums and contradicts the Act’s detailed structure. The government’s textual, precedential, and common‑law arguments failed to justify such a rule, and policy concerns about gaps in §3583(i)’s warrant requirement must be addressed by Congress, not judicial invention. Justice Gorsuch wrote for the Court; Justice Alito dissented.