United States v. Don Dowling

JOHN R. BROWN, Circuit Judge:

The sole issue before us is whether 18 U.S.C. § 3585(b) allows credit for time spent in official detention to reduce a term of probation.

Dowling, who pleaded guilty to misprision of a felony, argues that the time he served in Parish Prison prior to his sentencing should be credited towards the community confinement portion of the three year sentence of probation he eventually received. Because Dowling’s halfway house confinement is merely a special condition of his probation, rather than a term of imprisonment, no credit may apply to reduce his sentence. We…