4th Cir.

UNITED STATES OF AMERICA v. SAMUEL XUX-MUCU

June 25, 2026 ·25-4315 ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fourth Circuit dismissed an appeal challenging a term of supervised release. The court found the case moot because the appellant had completed his supervised release term while the appeal was pending.

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Background

Samuel Xux-Mucu appealed the district court’s imposition of a one-year term of supervised release following his conviction for possession of fraudulent immigration documents. The district court had sentenced him to time served and ordered his removal from the United States. While his appeal was pending, he completed the full term of his supervised release.

The court’s reasoning

The court held that the challenge to the sentence became moot when the entire sentence, including the term of supervised release, had been served. The court cited United States versus Ketter to support this conclusion. The court also noted that oral argument was unnecessary as the facts and legal contentions were adequately presented in the written materials.

What it means going forward

Appellants challenging supervised release terms must ensure their appeals are resolved before completing the term, or the case will be dismissed as moot.