Background
Devin Allen Wolfe appealed after the district court revoked his supervised release for the third time. He challenged the reimposition of three conditions of supervised release, arguing they violated his constitutional rights and involved a greater deprivation of liberty than reasonably necessary.
The court’s reasoning
The court concluded that Wolfe is barred from challenging the reimposed conditions because an objection to the court reimposing old supervised release conditions amounts to an improper collateral attack of the underlying sentence. The court further determined that even assuming no waiver or forfeiture, the district court did not err, plainly or otherwise, by imposing the conditions.
What it means going forward
Defendants cannot challenge the reimposition of supervised release conditions that were part of their original sentence after a revocation, as such challenges are treated as improper collateral attacks on the underlying sentence.
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