Rico v. United States

607 U. S. 609 (2026) · 3/25/26

The Sentencing Reform Act of 1984 does not authorize a rule automatically extending a defendant’s term of supervised release when the defendant fails to report to a probation officer.

A criminal defendant, on supervised release from federal prison, must comply with various conditions—both mandatory (commit no more crimes, see 18 U. S. C. § 3583(d)) and discretionary (commonly, “report to a probation officer as directed” and “notify the probation officer promptly of any change in address,” §§ 3563(b)(15), (17)). Violating a prescribed condition may result in the revocation of supervised release and a return to prison, § 3583(e)(3), as well as an additional “term of supervised release after imprisonment,” § 3583(h). After petitioner Isabel Rico violated the terms of her…

Held: The Sentencing Reform Act does not authorize a rule automatically extending a defendant's term of supervised release when the defendant absconds. Pp. 614–623. (a) What the Ninth Circuit's challenged rule really does is use a defendant's abscondment to extend (not toll) the period of supervised release beyond what a judge has ordered. Automatically extending a term of supervised release is not among the many tools the Sentencing Reform Act provides courts to address defendants who fail to report or otherwise violate their supervised release conditions. The Act instructs that a term of…