Detainers – Interstate Agreement on Detainers – Inapplicable to Parole

¶25      Pharm also argues that his Nevada parole is "imprisonment," as that term is used in the IAD. Imprisonment is not defined in the IAD. Therefore, it is defined according to its common meaning.  Perrin , 444 U.S. at 42 (stating that unless otherwise defined, words will be interpreted as taking their common meaning) (citation omitted)). Federal courts have defined imprisonment as "that definable period of time during which a prisoner must be confined in order to complete or satisfy the  prison term or sentence  which has been ordered."  United States v. Dobson , 585 F.2d 55, 58-59 (3rd Cir. 1978) (emphasis in original);  see also   United States  v. Reed , 620 F.2d 709, 711 (9th Cir. 1980) (concluding a person on parole is not imprisoned under the IAD).…¶27      In addition, if the definition of imprisonment under the IAD were interpreted to include both actual confinement and extended supervision or parole, a prisoner sentenced to parole for life in a sending state would remain indefinitely in the sending state and would never be eligible to serve his or her sentence in the receiving state. This result is not in accord with the plain language of the IAD.  State ex rel. Otterstetter v. McManus , 243 N.W.2d 730, 732-33 (Minn. 1976).  <11>