Anderson v. Corall
Headline: Court allowed a parole board to revoke a parole and require a man to serve the rest of his sentence, ruling time spent on parole does not shorten the original prison term.
Holding: The Court held that a parolee remains in legal custody, parole time does not shorten the sentence, and the parole board may revoke parole and require serving the remaining term without credit for parole time.
- Allows parole boards to revoke parole and require serving remaining sentences without credit for parole time.
- Treats time on parole as custody but not service when parole is revoked.
Summary
Background
A man named Arthur Corail was convicted on November 25, 1914 of breaking into a post office and sentenced to three years at the federal Leavenworth penitentiary. He was paroled on February 24, 1916 under federal parole laws. The warden issued a warrant in June 1916 charging a parole violation, but before he was retaken Corail was convicted in Chicago in October 1916 and sent to the Joliet, Illinois, penitentiary until about December 1919. After his release he was retaken on December 17, 1919, and in January 1920 the parole board revoked and terminated his parole. Corail sought habeas corpus relief and the lower courts ordered his discharge before the case reached the Supreme Court.
Reasoning
The Court considered whether time spent out on parole should count toward the original sentence and whether the parole board could revoke parole and require the prisoner to serve the remaining term without credit for parole time. The Court held that parole keeps the prisoner in the legal custody and control of the warden while on parole. A violation and subsequent conviction outside that custody interrupts service much like an escape. Under §6 of the statute the board may in its discretion revoke parole and require the prisoner to serve the remainder of the original sentence without deducting the time he was out on parole. The Court therefore found the sentence had not expired and the board’s action was valid.
Real world impact
The decision means people released on federal parole remain legally in custody and do not automatically shorten their prison term by being free on parole. If parole is revoked, the person can be returned to prison to serve the remaining sentence without credit for time spent on parole. The Supreme Court reversed the lower court and ordered Corail returned to Leavenworth.
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