Supervised Release

United States v. Albi Doka (2d Cir. April 2020)

Upon the defendant's appeal of his revocation of supervised release, the Second Circuit held that the Supreme Court's decision in United States v. Haymond did not overrule its prior precedent that district courts may engage in fact-finding when revoking a defendant's supervised release and imposing an additional term of imprisonment under 18 U.S.C. § 3583(e)(3).

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United States v. Ronald Samuel Jackson (4th Cir. March 2020)

The Court affirmed the defendant's reduced sentence under the First Step Act where the sentencing court sentenced the defendant to time served, and not less time than he had already served, in order to prevent the defendant from "banking" the excess time and applying it in a potential future revocation of his supervise release.

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United States v. Roger William Campbell II (9th Cir. September 2019)

The Court affirmed the district court's order sentencing the defendant to consecutive terms of imprisonment for violating his supervised release. Even though the district court had initially imposed concurrent terms of imprisonment and supervised release, the Guidelines allow a sentencing court to impose consecutive or concurrent sentences following the revocation of supervised release.

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United States v. Jon Julian Cabral (10th Cir. June 2019)

The Court struck a defendant's condition of supervised release that allowed the probation officer to determine whether the defendant poses a risk to third parties and then require the defendant to notify those third parties, holding that this was an improper delegation of judicial authority to the probation officer.

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United States v. William Block (7th Cir. June 2019)

The Court held that the district court lacked jurisdiction to revoke the defendant's supervised release since the defendant was not served with a formal revocation notice until after he had served the rest of his term of supervised release in custody while awaiting the revocation proceeding. The Court also rejected the Government’s argument that the defendant’s supervised release term was tolled once he was detained with two months left in the term.

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