Document Type

Article

Publication Date

11-2025

Abstract

Isabel Rico was serving a term of supervised release when she absconded from federal supervision. Years later, the government sought to revoke her release, arguing that her fugitive status “tolled” her supervised-release term. The Ninth Circuit agreed. Other circuits, however, have rejected the fugitive-tolling doctrine in the supervised-release context. The Supreme Court will now decide whether federal courts may judicially adopt fugitive tolling, or whether Congress’s silence in the supervised-release statute forecloses it.

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