the meaning of this definition. Criminal penalties are provided in 31 U.S.C. § 5322(a): “A person willfully violating this sub-chapter or a regulation prescribed under this subchapter ... shall be fined not more than $250,000, or imprison[ed for] not more than five years, or both.” 5 . Peck has completed his prison term since his petition was denied, see supra note 1, and is presently serving a three-year term of supervised release. Although he is no longer in prison, a term of supervised release, which carries with it the possibility of revocation and additional jail time, satisfies the "in custody” requirement of § 2255. See Jones v. Cunningham, 371 U.S. 236, 240-43, 83 S.Ct. 373, 375-77, 9 L.Ed.2d 285 (1963) (parole); cf. Scanio v. United States, 37 F.3d 858, 860 (2d Cir.1994) (<HOLDING>). 6 . Neither Frady nor Campino precisely
holding that upon expiration of period of supervised release habeas petitioner was no longer in custody holding that term of supervised release was not automatically terminated when defendant was deported from united states and thus defendants subsequent commission of another offense illegal reentry after deportation prior to expiration of term of supervised release violated condition of supervised release that defendant commit no new offenses holding that invitederror doctrine precludes defendant from challenging sentence of supervised release where defendant requested sentence of supervised release holding that further supervised release may be ordered as a sentence for violation of supervised release holding term of supervised release tolled while defendant was in state custody