Background
In 2018, Anthony Steven Price pleaded guilty to Hobbs Act robbery and being a felon in possession of a firearm. He was sentenced to prison and supervised release. While serving his sentence, he fled custody and was later sentenced for escape. After his release in May 2025, Price was involved in a physical altercation in Muskogee, Oklahoma, where he struck a man with an object, causing significant injury. He was charged with assault and battery with a dangerous weapon. His probation officer filed petitions to revoke his supervised release based on the new crime and possession of a weapon. The district court found by a preponderance of the evidence that Price violated the terms of his release and sentenced him to additional prison time.
The court’s reasoning
The court reviewed the district court’s findings for clear error and found them supported by the police report and testimony from the probation officer. The court noted that the district court acted within its province to determine witness credibility, rejecting the defendant’s testimony that he used only his fists. Regarding the hearsay argument, the court explained that revocation hearings allow for flexible evidence, including letters and affidavits. The court further held that because the defendant did not object to the hearsay evidence or assert his right to cross-examine witnesses at the hearing, any error was not plain and could not be reversed.
What it means going forward
The decision reinforces that district courts have broad discretion to accept hearsay evidence in supervised release revocation hearings and that defendants must timely object to preserve confrontation rights. It confirms that factual findings based on police reports and witness testimony regarding new criminal conduct will be upheld if supported by the record.
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