William Waters appealed a district court judgment that revoked his supervised release and imposed an 11-month term of imprisonment followed by 48 months of supervised release. His appointed counsel filed an Anders brief, stating there were no meritorious grounds for appeal but questioning the reasonableness of the sentence. The core dispute centered on whether the district court properly explained the specific conditions of his new supervised release term during the oral pronouncement at the revocation hearing. The court noted that while the district judge stated the terms would be the same as Waters's prior supervised release, the written judgment and the oral explanation did not align, creating a procedural defect under Fourth Circuit precedent.
The court applied the rule established in United States v. Rogers, which requires that any non-mandatory condition of supervised release must be included in the court's oral pronouncement of the sentence in open court. The district court's statement that the terms would be the same as Waters's prior release was insufficient because the court failed to explain why it imposed those specific discretionary conditions. Furthermore, the court found that the district court could not satisfy its obligation through incorporation because the written revocation judgment did not include the purportedly incorporated prior conditions. The record showed significant discrepancies between the standard conditions imposed in 2014 and those in the 2024 judgment, including conditions that appeared in one but not the other and provisions with materially different language. While the court affirmed the revocation decision itself, it held that a Rogers error mandates vacating the entire sentence and remanding for full resentencing to ensure the defendant receives a properly explained sentence.
The judgment is affirmed in part regarding the revocation of supervised release, but the sentence is vacated in part. The case is remanded to the district court for full resentencing. On remand, the district court must orally pronounce and explain all discretionary conditions of supervised release in open court to comply with United States v. Rogers. The court also instructed counsel to inform Waters of his right to petition the Supreme Court for further review.
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