Extra punishment for escape
Aaron Davis Reed v. United States
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Aaron Davis Reed asked whether counting the same escape from custody as an escape-status point under federal sentencing guidelines violates the Fifth Amendment’s ban on multiple punishments.
- Who it affects
- The denial ended Reed’s request for Supreme Court review, but the Court did not decide his challenge to the sentencing point.
Summary: written with AI from the case record.

What it's about
The Supreme Court refused to hear his case (denied review) and did not decide that question.
Reed’s question was whether the same escape could count both as his crime of conviction and as an added point under federal sentencing rules.
Question presented
When a defendant’s offense of conviction is escape from custody, does adding an escape status point under U.S.S.G. § 4A1.1(e) – based on that same escape – violate the defendant’s right not to be subjected to multiple punishments under the Fifth Amendment Double Jeopardy Clause.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
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.