Maurice Coleman appealed a district court judgment that revoked his term of supervised release and sentenced him to 18 months of imprisonment. The revocation was based on his violation of supervised release conditions, specifically the possession of a firearm, which triggers mandatory revocation under 18 U.S.C. § 3583(g). For the first time on appeal, Coleman challenged the constitutionality of this statute, arguing that it violates the Sixth Amendment right to a jury trial and the requirement of proof beyond a reasonable doubt, relying on the Supreme Court's decision in United States v. Haymond. However, the government moved for summary affirmance, noting that the Fifth Circuit had already addressed and rejected this exact constitutional argument in its 2020 decision, United States v. Garner.
The court focused on the binding precedent established in United States v. Garner, 969 F.3d 550 (5th Cir. 2020). In Garner, the Fifth Circuit explicitly rejected the argument that 18 U.S.C. § 3583(g) is unconstitutional under Haymond. The court noted that Coleman acknowledged this precedent but asserted the issue only to preserve it for further review. Because the legal question regarding the statute's constitutionality under the Sixth Amendment was already settled by Garner, the court determined that Coleman's sole argument on appeal was foreclosed. Consequently, the court found that summary affirmance was proper under Groendyke Transp., Inc. v. Davis, granting the government's motion without needing to reach the merits of the constitutional claim.
The district court's judgment revoking Coleman's supervised release and imposing the 18-month sentence remains in full effect. Coleman must serve the imposed prison term. The decision reinforces that challenges to the constitutionality of 18 U.S.C. § 3583(g) based on Haymond are foreclosed in the Fifth Circuit until the Supreme Court or the Fifth Circuit itself overturns the Garner precedent.
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