LeSean Roberts was convicted of drug offenses nearly two decades ago. Although he was originally subject to a mandatory life sentence, the President commuted his sentence in 2016 to 240 months. After serving 180 months, the district court reduced his custodial sentence to time served and imposed an eight-year period of supervised release. Since his release, Roberts has twice moved to end his supervision early. The district court denied his first motion and subsequently denied a second motion when his supervision term neared its halfway point. The denial of the second motion was memorialized by a marginal entry with an 'x' and a refiled probation supervision report that recommended denial based on Roberts being a 'career offender.' The district court did not provide any written analysis or explicitly adopt the report's reasoning in its order.
The Sixth Circuit applied the standard established in United States v. Tavarez, which requires that the record demonstrate the district court considered the relevant 18 U.S.C. § 3553(a) factors before denying an early termination motion. The court reasoned that a district court abuses its discretion when the record fails to show it considered the parties' arguments or had a reasoned basis for its decision. In this case, the district court's order consisted only of a checkmark and a referral to a probation report. The court held that this was insufficient because it provided 'no indication' that the court considered the relevant sentencing factors. The court noted that while the probation report recited the § 3553(a) factors, the district court's orders did not 'explicitly' adopt that analysis. Furthermore, the lack of analysis created ambiguity regarding whether the district court relied on an erroneous classification of Roberts as a career offender, a status the court had previously found improper. Without explicit reasoning, the appellate court could not discern how or why the denial comported with the statutory factors.
The district court's order denying the motion to terminate supervised release is vacated, and the case is remanded for a new ruling. The district court must now issue a decision that includes a reasoned analysis explicitly addressing the 18 U.S.C. § 3553(a) factors. This decision clarifies that procedural shortcuts, such as checkmarks or unadopted probation reports, are insufficient to satisfy the requirement for a reasoned basis in supervised release termination cases. The unresolved question remains whether the district court will grant termination upon remand, as the court must now weigh the statutory factors with proper analysis.
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