Must Federal Parole Determination Hearings Be Held in Person?

Yesterday, in Terrell v. United States, the U.S. Court of Appeals held that the United States Parole Commission cannot use video conferencing to conduct parole determination hearings. Rather, under 18 U.S.C. ยง 4208(e), such proceedings must be held in person. Of note, according to the opinion this was a question of first impression for the federal courts of appeals.