Luthor was jailed at the end of The Phoenix. As far as I recall (and it's been a while) he stayed there until he arranged for the clone of the President to sign a prison release form for him in I Now Pronounce You.

LabRat smile



Athos: If you'd told us what you were doing, we might have been able to plan this properly.
Aramis: Yes, sorry.
Athos: No, no, by all means, let's keep things suicidal.


The Musketeers