Robert Scott Moreland appeals the district court’s denial of his petition for a writ of habeas corpus under 28 U.S.C. § 2255. Moreland argues that he should receive credit on his sentence for time spent in a halfway house while awaiting trial and sentence. Because Moreland was in official detention while at the halfway house, we reverse and remand with direction to credit Moreland for time spent at the halfway house.
Moreland was indicted on July 26, 1989 and charged with two counts of bank fraud in violation of 18 U.S.C. § 1344 and two counts of using false social security cards in violation of 42 U.S.C. § 408(g)(2). He was arrested on July 28, 1989 and held in jail until September 5, 1989, when he was released on bond and ordered to reside at the Reentry Services Community Treatment Center (RSCTC) pending resolution of the criminal action brought against him. While at RSCTC, Moreland was required to obey all rules of the center,1 and was required to seek employment at the Center’s direction. Moreland was not allowed to leave the RSCTC grounds for the first two weeks he was at the Center. During the next two months, the Center gradually increased the amount of time Moreland could be away from the Center. Throughout his stay at RSCTC, however, Moreland was required to abide by at least a midnight to 8:00 a.m. curfew.2
On October 30, 1989, Moreland pleaded guilty to one count of fraud. On February 2, 1990, the court sentenced him to eighteen months imprisonment. From September 5, 1989 until March 12, 1990, when Moreland began serving his sentence at a federal prison, Moreland resided at RSCTC. At the federal prison, Moreland filed a petition requesting that the 150 days he spent at RSCTC prior to sentencing be credited against his eighteen-month sentence. After the Bureau of Prisons (BOP) denied this request, Moreland petitioned the district court for habeas relief. The district court refused to grant this relief because it determined that Moreland was not in “official detention” while at RSCTC.
On appeal, Moreland argues that his pre-sentencing detention at RSCTC was “official detention” within the meaning of 18 U.S.C. § 3585(b) (1988)3 and that the denial of sentence credit for the presentencing detention violated the equal protection *692clause because other prisoners residing at RSCTC received sentence credit for such residence. The government argues that the court properly denied credit because halfway houses do not fall under the statutory definition of official detention. It further argues that Moreland and the prisoners at RSCTC who received sentence credit were not similarly situated, because More-land had not yet been sentenced and the other prisoners had. The government thus claims that because Moreland and the other halfway house residents were not similarly situated, failure to treat them similarly did not violate the equal protection clause.
Congress has stated that “[a] defendant shall be given credit toward the service of a term of imprisonment for any time he has spent in official detention prior to the date the sentence commences.” 18 U.S.C. § 3585(b). Congress did not, however, provide a clear definition of “official detention.” Moreland argues that the plain meaning of “detention” describes the time he spent at RSCTC and that he therefore should receive § 3585(b) (1988) credit. We agree. Certainly there was “detention,” and it can hardly be called unofficial.
There is a conflict among the circuits on the question. The Fourth, Seventh, and Tenth Circuits are of the view that “official detention” means full physical incarceration. See United States v. Insley, 927 F.2d 185, 186 (4th Cir.1991) (appeal bond that partially restricted defendant to parents’ house not official detention); Ramsey v. Brennan, 878 F.2d 995, 996 (7th Cir.1989); United States v. Woods, 888 F.2d 653, 655 (10th Cir.1989), cert. denied, — U.S. -, 110 S.Ct. 1301, 108 L.Ed.2d 478 (1990). In reaching its decision, the Seventh Circuit relied on the following BOP policy statement:
Time spent in residence in a residential community center ... as a condition of bail or bond ... is not creditable as jail time since the degree of restraint provided by residence in a community center is not sufficient restraint to constitute custody within the meaning or intent of 18 U.S.C. § 3568.4
Brennan, 878 F.2d at 996 (quoting BOP Policy Statement No. 5880.24(5)(b)(5)).
The Ninth Circuit, however, has taken the position that the restrictions of a halfway house were “simply top close to incarceration to permit a distinction for purposes of credit against his sentence” when residents were subject to its regulations, to drug testing, to curfews, and to work agreements. Brown v. Rison, 895 F.2d 533, 536 (9th Cir.1990). While acknowledging their responsibility to defer to the BOP's interpretation of “official detention,” the Ninth Circuit concluded that such deference was unnecessary when the BOP’s interpretation was unreasonable and “contrary to the considerations of fairness that must have underlain Congress’ provision of credit for time served.” Id. See also Demarest v. Manspeaker, — U.S. -, 111 S.Ct. 599, 603, 112 L.Ed.2d 608 (1991) (no deference accorded to administrative interpretation of a statute that was contrary to the statute’s plain language).
The restrictions placed on Moreland are similar to those in Brown.. As with Brown, Moreland was subject to 24-hour supervision by the center, which was acting as an agent of the criminal justice system, and was physically incarcerated there for a substantial part of each day for 150 days. Brown, 895 F.2d at 536. Indeed, for part of his confinement at RSCTC, Moreland was subject to a stricter curfew than that in Brown. The restrictions placed on Moreland are similar to those placed on jail prisoners who have work-release privileges, and it cannot be contended that such prisoners are not in “official detention.” We agree with the Ninth Circuit that the BOP’s interpretation is unreasonable or contrary to considerations of fairness. See also United States v. Fernandez, No. 89-234-33, 1990 WL 102803 (E.D.Pa. July 16, 1990) (following Brown v. Rison). But cf. Insley, 927 F.2d at 187 (distinguishing *693Brown because Brown involved more restrictive conditions).
As the dissenting opinion points out, Moreland was granted a conditional release within the meaning of 18 U.S.C. 31425 when the Magistrate-Judge released him on bond and ordered him to be held in custody at RSCTC and to obey its rules. The question, however, is not whether Moreland was “detained” within the meaning of the Bail Reform Act, but whether the time he served in custody at the RSCTC was “official detention” under 18 U.S.C. § 3585(b)(1). As even the BOP policy statement recognizes, “the degree of restraint provided by residence in a community center” is the operative question here. We do not see why terms used in the Bail Reform Act apply to the statute at issue here, and the dissenting opinion does not provide a reason.
Even if the language of the Bail Reform Act were any guide to what Congress meant in its statutes concerning sentence credit, the Bail Reform Act’s repeated references to “custody” in the context of conditional release support the conclusion that some defendants who have been held in restrictive “custody” are entitled to sentence credit. As the dissent notes, the Bail Reform Act permits a judicial officer to “release” a defendant under conditions that require the defendant to be placed in the custody of a designated person, return to custody for specified hours, and satisfy other conditions the judicial officer deems necessary. See 18 U.S.C. §§ 3142(c)(l)(B)(i)-3142(c)(l)(B)(xiv) (1988). The predecessor statute to 18 U.S.C. § 3585 stated that those “in custody” were entitled to sentence credit, so under the dissent’s reasoning, defendants granted conditional release but placed in “custody” under 18 U.S.C. § 3142 could also be granted sentence credit.6
A defendant subject to conditions of release, of course, is not automatically enti-tied to sentence credit. A defendant must demonstrate, as Moreland has, that he was subject to conditions closely approaching or equaling incarceration. Only those defendants released under highly restrictive conditions will be entitled to sentence credit. It is not enough to be subject to some conditions, such as electronic monitoring, a requirement to live with one’s parents, and a curfew. See Insley, 927 F.2d at 186. The defendant must also be in an institution and be subject to that institution’s jail-like rules, as here and in Brown, 895 F.2d at 534, 536.
Having decided that Moreland was in detention for the purposes of section 3585(b), we need not decide whether the policy of not granting credit to presentence residents while granting credit to prisoners finishing their sentences is disparate treatment of similarly situated groups without a rational basis for the disparity. See Woods, 888 F.2d at 656; Johnson v. Smith, 696 F.2d 1334, 1336-37 (11th Cir.1983). We simply note that there is no dispute that residents of the Center are under the same rules and conditions whether they are pre-sentence or post-sentence inmates..
Reversed and remanded for action consistent with this opinion.
. The rules included: no drugs, narcotics, or alcohol; no weapons, sharp instruments, or knives; random urine and breath tests; nightly bed checks; no smoking in room; limited visiting hours, with all visiting to take place in the center’s dining room; telephone use limited to ten minutes; and compulsory sign in and sign out. Moreland was required to provide an accurate address and telephone number of his destination when signing out, was expected to account for his whereabouts at all times while outside the center, and was subject to telephone checks during that time.
. The dissenting opinion suggests that Moreland had limited phone privileges during his midnight to 8:00 a.m. curfew, but the record indicates otherwise. According to the Center’s rules, Moreland was subject to "periodic bed checks ... throughout the night,” so the Center must have required residents at RSCTC to be in their rooms during the nightly curfew. It does not appear, however, that RSCTC residents had personal phones in their rooms, as the Rules refer only to use of “the residence telephone” (emphasis added).
. 18 U.S.C. § 3585(b) (1988) provides:
(b) Credit for prior custody. — A defendant shall be given credit toward the service of a term of imprisonment for any time he has spent in official detention prior to the date the sentence commences—
(1) as a result of the offense for which the sentence was imposed; ... that has not been credited against another sentence.
. 18 U.S.C. § 3568 is the predecessor to 18 U.S.C. § 3585. Section 3568 uses the phrase "in custody" instead of "in official detention.” The Tenth Circuit held that this difference does not affect the analysis for the purpose of determining whether time in a halfway house should be credited to a sentence, and we agree. See Woods, 888 F.2d at 654-55.
. The Bail Reform Act of 1984 and its amendments.
. Given the legislative history of 18 U.S.C. § 3585, the dissent does not and could not claim that Congress intended a different result by changing the phrasing from "in custody” to "in official detention.” See Woods, 888 F.2d at 655; supra note 4. Moreover, the present statute is still entitled "Credit for prior custody," see 18 U.S.C. § 3585(b) (emphasis added).