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Under 18 U.S.C. § 751, custody need only be minimal and an escape from the "constructive custody" of the Attorney General may constitute a violation thereof. United States v. Cluck, 542 F.2d 728, 731 (8th Cir.), cert. denied, 429 U.S. 986 (1976).
[cited in Criminal Resource Manual 1824; JM 9-69.500]
