Supreme Court Hears Dispute Over Supervised Release Conditions

The U.S. Supreme Court in Washington on Feb. 10, 2025. Madalina Vasiliu/The Epoch Times

The Supreme Court on Feb. 25 is considering what factors federal judges may weigh when revoking a person’s supervised release and sentencing him or her for violating release conditions.

In supervised release, a prisoner is released from custody but is under restricted freedom for a set period. During that time, they must follow specific conditions and be supervised by a probation officer. If they violate those conditions, they may be sent back to prison.

In Esteras v. United States, which the court agreed on Oct. 21, 2024, to hear, the justices are expected to examine a disagreement among several federal appeals courts over what factors judges may consider when sentencing someone for violating conditions of supervised release.

They will also determine whether judges may take into account factors not mentioned in the supervised release law, which includes Section 3583(e) of Title 18 of the U.S. Code.

The lead petitioner, Edgardo Esteras, who was convicted of an unspecified federal crime, said in his petition that the Supreme Court should take up his case because there is a split among federal courts of appeals that needs to be resolved.

Five courts of appeals have determined that federal district courts are allowed to look at factors identified in Section 3553(a)(2)(A) of the same statute, but four courts of appeals have decided they may not, according to the petition.

The factors in that section include the need for a sentence to reflect the seriousness of the crime, promote respect for the law, and render just punishment for the crime.

Prosecutors argued that courts of appeals may look at these factors and that “any modest disagreement among the courts of appeals on the question presented has no practical effect,” the petition said.

The case goes back to 2018 when Esteras entered a guilty plea to conspiracy to distribute heroin.

Sentencing guidelines provided for a sentence of 15 to 21 months but the federal district court sentenced him to 12 months in prison to be served in addition to 15 months in prison for violating probation for a previous federal drug trafficking conviction, and then to be followed by six years of supervised release.

In its Aug. 16, 2023, decision, the U.S. Court of Appeals for the Sixth Circuit referenced Esteras’s 2018 guilty plea.

The Sixth Circuit said the six-year term of supervised release started in January 2020. In January 2023, probation officials notified the district court that Esteras violated the conditions of his supervised release by committing acts of domestic violence and possessing a firearm. The officials later told the court that the new criminal charges had been dropped at the request of the victim.

When the district court looked at the government’s allegation that Esteras violated the terms of the supervised release, the court determined he had possessed a firearm but refused to find he had committed a new legal violation. The court revoked supervised release and sentenced him to 24 months in prison to be followed by three years of supervised release, the circuit court said.

Esteras objected to the district court considering the factors set out in Section 3553(a)(2)(A).

In its ruling, the Sixth Circuit cited its own United States v. Lewis precedent from 2007 which states “that it does not constitute reversible error to consider [Section] 3553(a)(2)(A) when imposing a sentence for violation of supervised release, even though this factor is not enumerated in [Section] 3583(e).”

The circuit court affirmed the district court.

In an Aug. 30, 2024, brief, then-Solicitor General Elizabeth Prelogar urged the Supreme Court to turn away Esteras’s petition.

The disagreement among the circuit courts “would not change the result of the petitioners’ cases, in which the district courts briefly referred to the Section 3553(a)(2)(A) factors while considering undisputedly permissible factors.”

Prelogar said the Supreme Court has “repeatedly denied review in other cases presenting this question,” and then listed five of those cases the high court decided not to review.

Esteras’s attorney, assistant federal public defender Christian Grostic of Cleveland, Ohio, declined to comment on the case.

The Epoch Times reached out for comment to the U.S. Department of Justice but did not receive a reply by publication time.