Esteras v. United States
Issues
When determining whether to revoke supervised release, does a district court commit error if it relies on 18 U.S.C. § 3553(a)(2)(A)’s sentencing factors despite their absence from 18 U.S.C § 3583(e)’s enumerated list?
This case asks the Court to determine whether a district court presiding over a revocation hearing under 18 U.S.C. § 3583(e) may consider the factors listed in 18 U.S.C. § 3553(a)(2)(A) despite their absence from Section 3583(e)’s enumerated list. Section 3553(a)(2)(A)’s sentencing factors include reflecting the seriousness of the offense, promoting respect for the law, and providing just punishment for the offense. Petitioner argues that Section 3583(e)’s list is exhaustive, and omission of the Section 3553(a)(2)(A) factors precludes a district court from considering them to determine revocation of supervised release. Respondent counters that the consideration factors set out in Section 3583 are not exhaustive, and the factors in Section 3553 may be relied upon by a district court when determining the modification or revocation of supervised release. This case touches on important questions regarding the purpose of supervised release, a court’s discretion to revoke and reimprison violators, and the impact that judicial discretion has on the carceral system.
Questions as Framed for the Court by the Parties
Whether, even though Congress excluded 18 U.S.C. § 3553(a)(2)(A) from 18 U.S.C. § 3583(e)’s list of factors to consider when revoking supervised release, a district court may rely on the Section 3553(a)(2)(A) factors when revoking supervised release.
In 1984, through the Sentencing Reform Act (codified at 18 U.S.C. § 3583), Congress abolished the federal parole system and created a new form of post-imprisonment supervision called supervised release. 18 U.S.C.
Additional Resources
- Brian Dowling, High Court Takes Case On Sentencing For Release Infractions, Law360 (October 21, 2024).
- Douglas A. Berman, Supreme Court grants cert on (im)permissible factors for revocation of supervised release, Sentencing Law And Policy (October 21, 2024).
- Defender Services Office Training Division, Supreme Court Grants Cert On Supervised Release Case, Administrative Office of the United States Courts (October 21, 2024).