H

 As the Supreme Court has recognized, federal courts are afforded 'broad discretion' to fashion an appropriate remedy in connection with a grant of habeas relief. See Hilton v. Braunskill, 481 U.S. 770, 775, 95 L. Ed. 2d 724, 107 S. Ct. 2113 (1987). The general habeas corpus statute, 28 U.S.C. § 2243, authorizes district courts to 'dispose of the [habeas petition] as law and justice require.' 28 U.S.C. § 2243.

Although the federal courts have the power to order immediate and unconditional release when a petitioner is held in custody illegally, the courts usually do not do so. See Simmons ...