Sentencing after revocation of supervised release; Whether the district court considered the conduct underlying defendant’s violation; 18 USC §§ 3583(e) & 3553(a)(2)(B)–(C); Sanctioning a defendant for breach of trust associated with the violation; United States v Morris; United States v Patterson; Substantive reasonableness; Supervised release condition prohibiting defendant from communicating with his longtime girlfriend
The court held that the district court did not “err by considering the seriousness of” defendant-Williams’s violation conduct in sentencing him after revoking his supervised release. It also rejected his substantive reasonableness challenge and concluded that the district court did not abuse its discretion in imposing s “supervised-release condition that prohibits him from communicating with his longtime girlfriend” (S.H.). While on supervised release for drug crimes, Williams committed multiple offenses, including defrauding a woman (R.A.) out of $300,000. The district court revoked his supervised release and sentenced him to 30 months in prison and 5 more years of supervised release, with the new condition. The court found that the record showed that while “the district court referenced the seriousness of Williams’s fraud scheme, it wasn’t seeking to punish him for that conduct.” Instead, it was discussed to “illustrate[] the need for ‘deterrence and protecting the public.’” Additionally, a district court “can sanction the defendant’s breach of trust associated with the violation.” Although a court cannot “consider retribution when revoking supervised release[,] . . . breach of trust isn’t about retribution or punishment. Instead, it concerns the ‘forward-looking relationship’ between the defendant and district court ‘that’s focused on helping him reintegrate into society.’” In violating supervised-release conditions, a defendant “breaches that trust.” The court added that “a defendant’s breach of trust directly relates to several factors that the supervised-release statute permits a district court to weigh when imposing a revocation sentence.” It also found that “Williams’s sentence was substantively reasonable. The district court carefully weighed the sentencing factors and concluded that a 30-month sentence was necessary ‘to deter’ Williams and ‘protect society from further crimes’ he might commit.” Further, it did not “put too much weight on the seriousness of his violation conduct” because his conduct showed “the pressing need to protect the public from similar scams.” Finally, the condition of supervised release as to S.H. was “directly related to protecting the public from Williams. First, S.H. was a ‘coequal’ in Williams’s efforts to defraud R.A.” In addition, he sent S.H. threatening text messages. Affirmed.
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