Background
The defendant pleaded guilty to Hobbs Act robbery and felon in possession of a firearm in 2018. He later fled custody and pleaded guilty to escape. After his release in May 2025, he was involved in an altercation in July 2025 where he allegedly struck a victim with an object, causing injury. He was charged with assault and battery with a dangerous weapon. The district court revoked his supervised release based on these new allegations.
The court’s reasoning
The appellate court found the district court’s factual findings were supported by the police report and testimony from a probation officer. The court noted that revocation hearings allow for flexible evidence rules, including hearsay, and that the defendant did not preserve the issue of confrontation rights for plain error review.
What it means going forward
The defendant’s supervised release was revoked, resulting in additional prison time for both the underlying robbery and escape convictions.
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