Background
Steven Flowers was sentenced in 2004 to 262 months of imprisonment and ten years of supervised release for possession with intent to distribute crack cocaine as a career offender. He was later granted compassionate release in 2020, reducing his supervised release term to eight years. In 2024, Flowers tested positive for marijuana, a violation he attributed to a mistaken belief that it was legal in Ohio. He moved for early termination of his supervised release in 2025, citing stable employment and housing, but the district court denied the motion.
The court’s reasoning
The court reviewed the district court’s decision for abuse of discretion under 18 U.S.C. Section 3583. The court found that the district court properly considered the Section 3553 factors and did not err by requiring exceptionally good behavior as a prerequisite. Although the court noted that the district court made an erroneous factual statement regarding the conditions of compassionate release, it held that the denial had a reasoned basis under the deferential standard of review.
We hold that, under the deferential standard of review we must apply, there was a reasoned basis for the district court’s conclusion.
United States v. Flowers, No. 25-4006 (6th Cir. May 28, 2026)
What it means going forward
Defendants seeking early termination of supervised release must demonstrate that their conduct outweighs the nature of their offense and criminal history, even if they have maintained stable employment and housing.
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