Extending supervision after prison
Rico v. United States
In brief
The Court rejected automatic extension of supervised-release terms based on a defendant's absconding.
- Where it stands
- Decided
Decided 8-1 · March 25, 2026 · Opinion by Justice Gorsuch
- What it’s about
- The Supreme Court ruled 8–1 for Isabel Rico, holding that the Sentencing Reform Act does not automatically extend a person’s supervised-release term when that person absconds.
- Who it affects
- People on supervised release who abscond cannot have their terms automatically extended under the fugitive-tolling doctrine. Federal courts must apply the limits the Court identified when calculating those terms.
Summary: written with AI from the case record.

What it's about
The Court reversed the Ninth Circuit, concluding that Congress did not authorize fugitive tolling beyond the supervision end date set by the court.
The decision limits use of the fugitive-tolling doctrine in federal supervised-release cases.
Question presented
Does the fugitive-tolling doctrine apply in the context of supervised release?
What the Court decided
The vote
From the opinions
““The Sentencing Reform Act does not authorize a rule automatically extending a defendant’s term of supervised release when the defendant absconds.””
What's next
The Ninth Circuit must reconsider Rico's case under the Supreme Court's decision. Lower courts and agencies must not automatically extend supervised-release terms on this basis.
Docket activity
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AI analysis generated: Opinion Summary
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Judgment REVERSED and case REMANDED. Gorsuch, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Sotomayor, Kagan, Kavanaugh, Barrett, and Jackson, JJ., joined. Alito, J., filed a dissenting opinion.
Opinion added: opinion
Opinion added: Opinion of the Court - NG
More questions
- What did the Supreme Court rule in Rico?
- The Court said the Sentencing Reform Act does not permit automatic extension of supervised release when a defendant absconds. It reversed the Ninth Circuit.
- Who is affected by the Rico decision?
- People on federal supervised release who abscond may be affected. Courts cannot automatically add time to their supervised-release terms under this doctrine.
- What happens next in Rico?
- The case returns to the Ninth Circuit for further proceedings. That court must apply the Supreme Court's rule against automatic extension.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.