(A)  In General.  An immigration hold is often viewed by the criminal authorities as a bar to the noncitizen prisoner’s participation in less restrictive alternatives to incarceration, such as half-way houses, early release programs, out-patient drug rehabilitation programs, and the like.  See § 6.19, supra.  A noncitizen’s immigration status and having an immigration hold placed can have other adverse consequences as well. 

Third Circuit

CRIM DEF - SENTENCE - SUPERVISED RELEASE - DISTRICT COURT HAS NO AUTHORITY TO TOLL PERIOD OF SUPERVISED RELEASE AFTER DEPORTATION UNTIL RETURN
United States v. Cole, 567 F.3d 110 (3d Cir. May 20, 2009) (district court had no authority to order that the supervised release term of illegal reentry sentence be tolled as long as defendant remained outside of the United States following his possible removal after his prison term, because tolling is not a "condition" of supervised release within the meaning of 28 U.S.C. 3583(d)).