Rico v. United States

Questions presented

SCOTUS records, cert granted 30 Jun 2025

Whether the fugitive-tolling doctrine applies in the context of supervised release.

Opinion summary

Etalia.ai summary of the majority opinion

The case asked whether a defendant’s term of supervised release automatically continues when she absconds, so that conduct committed after the court-ordered end date can still count as a supervised release violation. Writing for the Court, Justice Gorsuch said no. The Sentencing Reform Act does not authorize an automatic extension of supervised release for abscondment. The Court said the Act already gives judges specific tools for violations, including revocation, imprisonment, new supervised release, limited extension procedures, and true tolling during certain imprisonment, but it does not allow courts to add a judge-made rule extending supervision beyond the term ordered or beyond statutory maximums. The Court also rejected the government’s text, precedent, common-law, and policy arguments. The judgment was reversed and remanded.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Alito dissented. He said the case was simpler because the district judge had authority under the Sentencing Reform Act to consider petitioner’s January 2022 drug offense when choosing the revocation sentence, regardless of whether her supervised release had expired or been tolled. He argued the Sentencing Guidelines are advisory, the judge could consider the later offense under the § 3553(a) factors, and it made no difference that the judge started from a higher guideline range and then varied downward. He would have affirmed.