United States v. Goad, No. 14-3070 (8th Cir. 2015)
Annotate this CaseThe second time the district court revoked Goad’s supervised release, it sentenced him to five months in prison and ordered him to reside in a residential reentry center for 120 days after his release from prison. Within two months of his residency at the Hinzman Center, Goad absconded. Goad was soon arrested and indicted for escaping from custody, 18 U.S.C. 751(a). Goad moved to dismiss, contending section 751(a) does not criminalize his abscondence because he was not in “custody” while residing at the Hinzman Center. The district court denied his motion. Goad conditionally pled guilty. The Eighth Circuit affirmed. Nothing in section 751(a) suggests that the purpose of the confinement matters and the use of a residential reentry center during supervised release is no more “transitional” or “non-penological” than pre-release halfway houses.
Court Description: Riley, Author, with Loken and Shepherd, Circuit Judges] Criminal case - Criminal case. Residency in a residential reentry center as a condition of supervised release constitutes "custody" under 18 U.S.C. Sec. 751, and the district court did not err in denying defendant's motion to dismiss his indictment for escape from custody after he absconded from his residential placement.
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