He was due to be released this week but this has been held up after a Department of Corrections lodged an application to impose special release conditions.
This morning in the Whanganui District Court, Patterson's lawyer Jock Blathwayt said the special conditions being sought related to his earlier offending and the Parole Board was aware of this when it set the release conditions.
"There's nothing before the court today that wasn't before your honour and before the Parole Board a month or two before the sentencing was completed," he said.
Department of Corrections lawyer Sally Carter said the conditions could be tied to a "risk assessment" rather than to a specific offence.
Judge David Cameron reserved his decision, and did not say when it might be made.