Terrell Williams was originally sentenced in 2018 for conspiring to distribute cocaine, receiving a below-Guidelines prison term followed by five years of supervised release. During his supervision, Williams engaged in a multi-year scheme to defraud an acquaintance, R.A., by fabricating a kidnapping to obtain over $300,000. He also lied to his probation officer about the incident, used controlled substances, and faked drug tests by using someone else's urine. Additionally, he pled guilty to driving with a suspended license. Upon discovery of these violations, the district court revoked his supervised release and imposed a 30-month prison sentence, followed by five more years of supervision, including a condition prohibiting him from associating with his girlfriend, S.H., who assisted in the fraud.
The Sixth Circuit reviewed the sentence for abuse of discretion and the procedural objections for plain error. First, the court addressed Williams's argument that the district court impermissibly punished him for the underlying fraud. The court explained that while retribution for the crime is not a valid factor, a district court may consider the seriousness of a defendant's breach of trust. The opinion states that 'breach of trust isn't about retribution or punishment. Instead, it concerns the forward-looking relationship between the defendant and district court that's focused on helping him reintegrate into society.' Because Williams lied to his probation officer and engaged in a massive fraud scheme, his breach of trust was substantial, justifying a sentence focused on deterrence and public protection. Second, the court found the 30-month sentence substantively reasonable. The district court carefully weighed the factors, noting that Williams had received leniency originally based on trust, which he squandered. The sentence was necessary to protect R.A., who continued to believe Williams's lies, and to deter future crimes. Finally, the court upheld the condition prohibiting contact with S.H. The record showed S.H. was a 'coequal' in the fraud scheme and that Williams had sent her text messages threatening to kill her. The restriction was reasonably related to protecting the public and S.H. from further harm and did not unreasonably burden Williams's constitutional rights, as he could seek permission to communicate.
The decision reinforces that supervised release revocation sentences can be enhanced based on the severity of a defendant's breach of trust, even if the underlying conduct is not separately punished. It clarifies that courts may impose special conditions restricting contact with co-conspirators or individuals who have been threatened, provided the restriction is directly related to public safety and rehabilitation. Williams's sentence of 30 months is upheld, and he remains subject to the new supervised release conditions prohibiting contact with S.H.
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