United States v. Wilson – Do It For The Caselaw

Holding: The Fourth Circuit affirmed the district court's judgment revoking supervised release and imposing a thirty-month sentence.
Standard: abuse of discretion; plain unreasonableness
Vote: Unpublished per curiam opinion affirming the district court.
Practical effect: The decision reinforces that district courts may impose consecutive sentences upon revocation of concurrent terms of supervised release and that defendants may be found to have violated conditions even if they took no position on the specific violation.

The Fourth Circuit affirmed the district court's judgment revoking supervised release and imposing a thirty-month prison sentence. The court found no abuse of discretion in the revocation determination or the consecutive nature of the sentences.

Background

Devante N’Kee Wilson appealed the district court’s judgment revoking his supervised release and sentencing him to a total of thirty months’ imprisonment. Counsel filed a brief pursuant to Anders v. California stating there were no meritorious issues for appeal, while Wilson filed a pro se brief raising additional constitutional and reasonableness challenges.

The court’s reasoning

The court reviewed the revocation for abuse of discretion and the sentence for plain unreasonableness. It found no error in the district court’s determination that Wilson committed a violation on which he took no position. Regarding the sentence, the court concluded that running the two revocation sentences consecutively, even though Wilson was serving concurrent terms of supervised release, did not render the sentence plainly unreasonable.

Our review of a district court’s revocation of supervised release is for abuse of discretion, meaning that we review legal conclusions de novo and factual determinations for clear error.

United States v. Mills, 173 F.4th 182, 188 (4th Cir. 2026)

What it means going forward

The decision reinforces that district courts may impose consecutive sentences upon revocation of concurrent terms of supervised release and that defendants may be found to have violated conditions even if they took no position on the specific violation.