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The preventive detention provision of the 1984 Bail Reform Act, upheld by the Supreme Court in United States v. Salerno, 1 permits federal courts to detain defendants prior to trial on grounds of dangerousness. 2 Although the 1984 Act expands the permissible bases for holding defendants before trial,it retains the preference for conditional release4 mandated by its statutory predecessor, the Bail Reform Act of 1966. The

Limiting Preventive Detention Through Conditional Release: The Unfulfilled Promise of the 1982 Pretrial Services Act