Joseph Tyler v. United States

Tyler’s parole was revoked after he violated its conditions. The parole commission determined that upon revocation he must forfeit the credit he would otherwise have received for his “street time.” Unhappy with the resulting delay of his mandatory release date, Tyler contested the forfeiture by a federal habeas motion. He appeals its denial.

BACKGROUND

In 1983, the Superior Court for the District of Columbia accepted a guilty plea to robbery from Joseph Michael Tyler. He received an indeterminate sentence of three to nine years imprisonment and was incarcerated in Ray Brook, a federal correctional institution.

District of Columbia law applies because Tyler is a D.C. offender. Such an offender may be imprisoned in a federal, rather than a district, institution. D.C.Code Ann. § 24-425 (1990). Federal incarceration places the prisoner under the jurisdiction of the United States Parole Commission. See D.C.Code Ann. §§ 24-209, 24-206(b) (1990). Federal prison officials must apply D.C. parole law to determine the release dates of the district offenders they house. E.g., Walker v. Luther, 830 F.2d 1208, 1217 (2d Cir.1987).

The District of Columbia enacted its Good Time Credits Act of…