Guy Collins was sentenced in 2010 for conspiracy to distribute cocaine base, receiving a term of imprisonment followed by eight years of supervised release. After the First Step Act reduced his prison term, he began supervised release in 2022. Collins filed three motions for early termination. The district court denied the first motion despite acknowledging that further supervision was not needed for deterrence or public protection. It denied the second motion solely because Collins had not completed fifty percent of his term, citing a local custom. The third motion was denied again, with the court attempting to justify the denial by claiming the need for deterrence, a stance that directly contradicted its earlier finding in the first order. Collins appealed the second and third orders, arguing the court abused its discretion by mechanically applying its fifty-percent rule.
The Sixth Circuit analyzed whether the district court abused its discretion by applying a fifty-percent completion custom. Under 18 U.S.C. § 3583(e)(1), a court may terminate supervised release after one year if satisfied that the action is warranted by the defendant's conduct and the interest of justice, based on specific § 3553(a) factors. The court reasoned that while the time served is a relevant consideration, it cannot be the sole animating force behind a decision. A blanket rule or custom that refuses to consider motions until a certain percentage of the term is elapsed circumvents the statutory mandate for individualized inquiry. The court noted that the Second Order failed to mention any § 3553(a) factors, relying exclusively on the motion being premature. Furthermore, the Third Order's reasoning was flawed because it claimed a need for deterrence and public protection that directly contradicted the district court's own admission in the First Order that those needs were already met. The court emphasized that courts cannot add to the statutory one-year minimum without tying their decision to specific statutory factors, and a rigid time-served presumption contravenes the requirement for individualized consideration.
The district court's denials are vacated, and the case is remanded for the district court to re-evaluate Collins's eligibility for early termination. The lower court must now conduct a fresh, individualized assessment of the § 3553(a) factors, specifically focusing on Collins's rehabilitation and current circumstances, rather than applying a rigid fifty-percent rule. The decision clarifies that while time served is relevant, it cannot substitute for the statutory analysis of deterrence and public protection.
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