Moreland v. Federal Bureau of Prisons

Background

Two federal prisoners challenged how the Bureau of Prisons calculates good-time credits, which reduce a person’s time in prison. The dispute turns on whether the phrase "term of imprisonment" means the sentence a judge imposed or the actual time a prisoner serves. That difference changes credits by about a week for each year of a sentence and affects the number of days prisoners spend behind bars and the cost to taxpayers.

Reasoning

The Court refused to review the cases and therefore did not decide the legal question on the merits. Justice Stevens explained that many federal appeals courts have accepted or deferred to the Government’s interpretation, while other courts and a magistrate judge have read the statute differently. He noted statutory history, including a 1959 Congressional change that addressed a prior judicial ruling, and suggested the text and history point toward calculating credits from the sentence imposed. He also said the question deserves further study and that Congress could clarify the law.

Real world impact

Because the Court did not rule on the merits, current Bureau of Prisons practices and lower-court rulings remain in place for now. Well-behaved prisoners’ release dates, prison populations, and federal prison costs continue to depend on the interpretation used by prison officials and courts. Congress may choose to act to settle the matter, and the practical outcome could change if future courts or lawmakers reach a different conclusion.

Dissents or concurrances

Justice Stevens wrote separately to explain his reasons for denying review and to express his view that the statute’s text and history favor computing credits from the sentence imposed.