Jamel Williams pleaded guilty to ten counts of uttering counterfeit obligations, receiving a sentence of 36 months in prison followed by three years of supervised release. After his release, Williams violated his conditions multiple times, primarily through marijuana use and the issuance of fraudulent checks. Following a hearing where he admitted to these violations, the district court revoked his supervised release. The court sentenced him to 18 months of imprisonment, consecutive to his state sentence, and imposed an additional one-year term of supervised release. Williams appealed, challenging the reasonableness of the sentence and the legality of the new supervised release term.
The Sixth Circuit applied an abuse-of-discretion standard to review the reasonableness of the sentence. On procedural grounds, the court rejected Williams' argument that the district court failed to provide notice of an upward variance. The court clarified that Federal Rule of Criminal Procedure 32(h) governs departures, not variances, and even if it applied, the facts supporting the variance were contained in the presentence report and known to Williams. On substantive grounds, the court found the sentence reasonable because the district court adequately considered the 18 U.S.C. § 3553(a) factors, noting Williams' lengthy criminal history, his failure to learn from past sanctions, and the need for deterrence. The court deferred to the district court's decision to impose a consecutive sentence. However, regarding the supervised release term, the court applied the statutory limits of 18 U.S.C. § 3583(h). For a class C felony, the maximum supervised release is three years, reduced by any imprisonment time imposed upon revocation. Williams had already served 26 months in revocation sentences (8 months previously and 18 months now). Adding a new 12-month term would result in 38 months of supervised release, exceeding the 36-month statutory cap. The court held that the district court erred by imposing a term that exceeded this limit.
The 18-month prison sentence remains in effect, but the additional one-year supervised release term is removed. The case is remanded to the district court to reconsider whether to impose a new supervised release term. Any new term must be calculated so that the total supervised release time does not exceed the statutory maximum of three years minus the time already served in revocation imprisonment. This leaves open the question of whether the district court will impose any supervised release at all, or if it will impose a term that fits within the remaining statutory window.
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