Facts of the Case

Roy Lee Johnson had been serving time in federal prison for multiple drug and firearms felonies when two of his convictions were declared invalid. The District Court ordered his immediate release. Johnson's 3-year term of supervised release that was yet to be served on the remaining convictions then went into effect. As a result of serving time for the two invalid convictions, Johnson had served 2.5 years' too much prison time. After his release, Johnson filed a motion to credit the excess two and one-half years he was erroneously incarcerated toward his three-year supervised release sentence. The District Court denied relief, explaining that the supervised release commenced upon Johnson's actual release from incarceration, not before. In reversing, the Court of Appeals accepted Johnson's argument that his supervised release term commenced not on the day he left prison, but when his lawful term of imprisonment expired.

Question

May a federal criminal defendant's excess prison time be credited towards this supervised release term, reducing its length?

Conclusion

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that the length of a supervised release term cannot be reduced by reason of excess time served in prison. Justice Kennedy wrote for the Court that, "[t]he objectives of supervised release would be unfulfilled if excess prison time were to offset and reduce terms of supervised release." The Court found that Congress intended supervised release to assist individuals in their transition to community life and that supervised release fulfills rehabilitative ends, distinct from those served by incarceration.