 On December 11, 2012, McGowan was released to a halfway house in New York City.He was taken into custody again on April 4, 2013, several days after writing an article for the "Huffington Post" criticizing CMUs.The stated reason for McGowan's detention was that the "Huffington Post" article violated a regulation against inmates “publishing under a byline”; the Center for Constitutional Rights pointed out that this regulation had been declared unconstitutional, and McGowan was released back to a halfway house on April 5.