In Cox v. Pennsylvania Board of Probation and Parole, 507 Pa. 614, 620, 493 A.2d 680, 683 (1985) the Supreme Court explained that "all forms of parole involve some restraint on the parolee's liberty, and non-compliance with them can result in arrest and recommittal as a technical parole violator." Stated otherwise, the imposition of restraints on a parolee's liberty is part and parcel of being "at liberty on parole." In Cox, the Board argued that a parolee's attendance in a residential facility should always be considered "at liberty on parole" because it is a condition agreed to by the parolee. However, the Supreme Court declined the Board's invitation to issue a per se rule that all time spent in a residential facility as a condition of parole is time "at liberty on parole." Instead, the Supreme Court left the door open to a parolee to make the case that a particular residential facility is the equivalent of a prison, thereby entitling the parolee to sentence credit for time spent at that facility. However, the Supreme Court also established jurisprudential principles in Cox that make it difficult for a parolee to make such a case. These essential principles are as follows: Because a parolee does not enter a residential facility pursuant to a court order but, rather voluntarily agrees to do so "as part of his parole program, his attendance there is presumed to be at 'liberty on parole.'" Id. at 616, 493 A.2d 681. The presumption that attendance at a residential facility is "at liberty on parole" may be rebutted. However, it is the burden of the parolee to develop a factual record and to persuade the Board that the residential program he attended was a "prison equivalent precluding the conclusion that the parolee was at 'liberty on parole.'" Id. If the Board is not persuaded that the parolee did time in a "prison equivalent," courts should "not interfere with the Board's determination of that issue unless it acts arbitrarily or plainly abuses its discretion." Id. at 620, 493 A.2d at 683.