We'll hear argument first this morning in case 24, 1056, RICO versus United States.

Mr. Unikowski.

Mr. Chief Justice, and may it please the Court, the question in this case is not whether,

but instead how, to hold people accountable for absconding from supervised release.

The text and history of the Sentencing Reform Act established that Congress intended for revocation,

not fugitive tolling, to be the means of addressing abscondment.

To begin with the text, the effect of the government's position is that Ms. Rico was subject

to the conditions of supervised release

for a period exceeding the time specified in her judgment, and there's no textual support

for that result. The government claims that Ms. Rico wasn't serving her sentence at all

during the period of the abscondment, But that argument cannot be squared with the government's

simultaneous contention that Ms. Rico violated the conditions of supervisor release during that

period warranting an increased sentence. History supports Ms. Rico's position. Contrary to the

government's contention, there is no common law tradition of

fugitive tolling for parole. Instead, fugitive tolling for parole came to exist via a

1976 statute and a 1983 implementing regulation. But in the Sentencing Reform Act, Congress prospectively repealed that statute and enacted

nothing in its stead for supervised release while leaving it intact for legacy parole cases,

and it remains intact today. As a result, Congress has created a two-track scheme, parole with

fugitive tolling, and supervised release without it.

And we ask the Court to adhere to that dichotomy.

I welcome the Court's questions.

Well, Mr. Unikowski, the government seems to be arguing, making a simple point,

...