5th Cir.

United States v. Easley

March 19, 2026 ·25-10554 ·Per Curiam · By James Taylor

The Fifth Circuit affirmed the revocation of Calvin Easley's supervised release, holding that the district court did not abuse its discretion in finding he violated a mandatory condition by assaulting a pregnant person. The court concluded that viewing the evidence in the light most favorable to the government, a reasonable trier of fact could find it more likely than not that Easley committed the assault under Texas law.

Listen to this decision 0:00 / 1:33

Calvin Easley appealed the revocation of his term of supervised release following a hearing in the United States District Court for the Northern District of Texas. The core dispute centered on whether Easley violated mandatory condition number one of his supervised release, which prohibited him from assaulting a pregnant person. Easley argued that the district court erred in its factual finding regarding the assault. The government sought to uphold the revocation and the subsequent sentencing enhancement based on the severity of the violation.

The Fifth Circuit reviewed the district court's decision to revoke supervised release for abuse of discretion. In assessing the sufficiency of the evidence, the court mandated that it view the evidence and all reasonable inferences drawn from it in the light most favorable to the government. Applying this standard, the court determined that a reasonable trier of fact could conclude it was more likely than not that Easley committed an assault against a pregnant person under Texas Penal Code Section 22.01. Because the evidence supported the finding of a violation, the district court did not abuse its discretion in revoking Easley's supervised release. Consequently, the appellate court found no error in the district court's decision to sentence Easley according to the higher advisory guidelines range applicable to a Grade B violation.

The decision affirms the revocation of Easley's supervised release and the associated sentencing consequences. It reinforces the standard that appellate courts will not second-guess factual findings in revocation hearings if a reasonable trier of fact could support the government's version of events. The ruling confirms that violations involving assault on a pregnant person trigger the higher advisory guidelines range for Grade B violations.

Play