Matamoros v. Grams

Dist. Ct. did not err in denying defendant’s habeas petition challenging imposition of special parole term on drug conviction even though prison officials had erroneously issued defendant notice of discharge after defendant had completed regular parole of his sentence. Record showed that Dist. Ct. originally sentenced defendant to special parole term that was to be served after defendant had completed regular parole term of sentence, and that U.S. Parole Commission issued Certificate of Special Parole nunc pro tunc six hours prior to defendant committing unrelated armed robbery. Ct. rejected defendant’s claim that issuance of detainer (to be enforced after completion of armed robbery sentence) based on violation of special parole was improper on grounds that he received inadequate notice of special parole term since defendant had notice of special parole at original sentencing. Moreover, Ct. rejected defendant’s claim that Commission was equitably estopped from enforcing detainer where record showed at most existence of mere mistake in issuance of notice of discharge.