A defendant held in custody should receive credit toward the sentence imposed under provisions of the Sexual Psychopath Act (SPA), which states that a court must provide such credit for time spent in custody.

Shelton pled guilty to two counts of taking indecent liberties with a minor child. Prior to sentencing, Shelton compelled the Government to file a sexual psychopath statement. This statement, which must set forth any facts tending to show that the defendant was a sexual psychopath, serves to stay the underlying criminal proceedings in order to provide treatment. The trial court adjudicated Shelton a sexual psychopath, and ordered him committed as a patient to a mental hospital. Shelton filed to a motion to lift the stay of the proceedings and proceed to sentencing and the trial judge left open the question of time credit.

The Court of Appeals of the District of Columbia provided Shelton with credit as his time at the mental hospital constituted custody under the statute. In addition, the Court of Appeals held that the custody was a result of the sentence imposed in spite of the postponement of the sentencing hearing in this case during Shelton's commitment. The Court held that the criminal act and the hospital commitment under the Sexual Psychopath Act result from the same underlying factual predicate and therefore are linked in the resolution of the case by the trial judge.