Former media tycoon Conrad Black will have to wait until next month to find out if he can return to Canada.
A judge asked for more thorough financial information before she decides whether to allow him to return.
Black was in court yesterday after being released from a US jail on $2m bail (€1.55m).
He walked free from the minimum security prison in Coleman, Florida, on Wednesday after serving two years and four months of a six-and-a-half-year sentence for defrauding investors out of millions of dollars.
District Judge Amy St Eve in Chicago ordered him to surrender his expired passport.
She also said he cannot obtain a new passport without the court's permission.
Black's lawyers said he wanted to return to Toronto because of media attention and because his wife had medical conditions which made their Florida home unsuitable.
The judge ordered him to return to court on August 16.
She said: "I want more certainty. I need more to make a fully informed decision."
Black left the court without speaking to reporters and was whisked away in a waiting car.
He was freed after businessman and friend Roger Hertog posted the bail.
The 65-year-old peer was granted bail on Monday by the Court of Appeals, pending an appeal against his conviction for fraud and obstruction of justice.
The decision came after a US Supreme Court ruling weakened the "honest services" law which was central to the case brought by prosecutors.
It will now be left to a lower court to decide whether his conviction should be overturned.
The former head of the Hollinger International media empire was convicted with three other former executives of defrauding shareholders out of 6.1m (€4.72m).
He was also convicted of obstruction of justice after he was seen carrying boxes of documents out of his offices, loading them into his car and driving away. The documents were sought by US government investigators.
Hollinger International once owned the Daily Telegraph, Chicago Sun-Times, Jerusalem Post and hundreds of community papers in the US and Canada.
Black renounced his Canadian citizenship to become a member of the British House of Lords and was known for a grand lifestyle.