United States v. Wilson
503 U.S. 329 (1992)
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Rule of Law:
Under 18 U.S.C. § 3585(b), the Attorney General, through the Bureau of Prisons, is responsible for calculating credit for time spent in pre-sentence detention after the defendant has begun serving their federal sentence; this calculation is not performed by the district court at the time of sentencing.
Facts:
- In the summer and fall of 1988, Richard Wilson committed several crimes in Putnam County, Tennessee.
- Tennessee authorities arrested Wilson on October 5, 1988, and he was held in jail pending the resolution of both state and federal criminal prosecutions.
- On November 29, 1989, a United States District Court sentenced Wilson to 96 months of imprisonment for his federal crimes.
- On December 12, 1989, a Tennessee trial court sentenced Wilson for his state crimes.
- In its sentencing, the Tennessee court granted Wilson 429 days of credit for the time he had been detained prior to sentencing.
- Later on December 12, 1989, Tennessee authorities transferred Wilson to federal custody, at which point he began serving his federal sentence.
Procedural Posture:
- Richard Wilson was prosecuted in the U.S. District Court for the Middle District of Tennessee, which is the trial court.
- At sentencing, the District Court denied Wilson's request for credit for time served in state custody prior to his federal sentence.
- Wilson, as appellant, appealed the denial to the U.S. Court of Appeals for the Sixth Circuit, an intermediate appellate court.
- The Court of Appeals reversed the District Court's decision, ruling that the credit should have been awarded by the sentencing court.
- The United States, as petitioner, sought and was granted a writ of certiorari from the U.S. Supreme Court to review the decision of the Court of Appeals.
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Issue:
Does 18 U.S.C. § 3585(b) authorize a district court to calculate and award credit for time served in pre-sentence detention at the time of sentencing?
Opinions:
Majority - Justice Thomas
No. The authority to compute credit for pre-sentence detention under 18 U.S.C. § 3585(b) rests with the Attorney General, not the sentencing court. The statute's use of past and present perfect tenses ('has spent,' 'was imposed') indicates that the calculation must occur after the defendant commences their sentence, as the total amount of pre-sentence detention cannot be known until that point. Furthermore, the provision barring credit that 'has not been credited against another sentence' would lead to arbitrary results if applied at sentencing, as the outcome would depend on the contingent timing of state versus federal court proceedings. The long-standing administrative practice of the Attorney General, through the Bureau of Prisons (BOP), computing such credit under the predecessor statute should continue, as the passive voice of the new statute does not signal a clear congressional intent to upend this established and practical procedure.
Dissenting - Justice Stevens
Yes. The district court has the authority to calculate the credit at sentencing. The statute's use of the passive voice ('shall be given') does not assign the duty to a specific actor, providing flexibility for either the court or the Attorney General to make the determination as circumstances require. Placing this authority with the court aligns with the statutory context, where courts make all other key sentencing decisions, and promotes the Sentencing Reform Act's goals of certainty and fairness. A defendant has counsel at sentencing, ensuring any disputes are resolved in a formal adversarial proceeding, which is preferable to forcing an inmate to navigate a complex administrative process from prison.
Analysis:
This decision clarifies a key procedural ambiguity in the Sentencing Reform Act of 1984, vesting the administrative power to calculate sentence credits squarely with the executive branch (Attorney General/BOP). It solidifies a uniform, post-sentencing administrative process for credit calculation, preventing disparate outcomes based on the timing of state and federal sentencings. The ruling emphasizes textual interpretation based on verb tense and practical consequences over arguments about statutory context, requiring inmates to exhaust administrative remedies with the BOP before seeking judicial review of credit disputes.
