North Carolina Lawyers Weekly

Apr 30, 2026

Revocation sentence vacated for failure to address mitigation argument

A supervised release sentence was procedurally unreasonable where the U.S. District Court failed to address the defendant’s non-frivolous argument that he had effectively served an additional 19 months […]

Apr 24, 2026

Clinical evidence supports renewed pornography ban on supervised release

The 4th U.S. Circuit Court of Appeals affirmed the reimposition of a pornography ban as a condition of supervised release, holding that new, individualized clinical evidence tied the […]

Apr 15, 2026

New clinical evidence supports renewed pornography ban on supervised release

The 4th U.S. Circuit Court of Appeals affirmed the reimposition of a pornography ban as a condition of supervised release for a defendant convicted of transporting child sexual abuse material, […]

Mar 30, 2026

‘Abscondment’ doesn’t toll term of supervised release, SCOTUS rules

A criminal defendant did not subject herself to an automatic extension of her term of supervised release by absconding after failing to report a change of residence to her probation […]

Jul 17, 2025

SCOTUS wrap-up: factors for revoking supervised release narrowed

The U.S. Supreme Court ruled a federal judge could not consider the need to “promote respect for the law” in deciding whether to revoke a drug defendant’s supervised release.

Mar 27, 2025

4th Circuit: Hearsay evidence wrongly admitted

Where the district court admitted hearsay evidence during the releasee’s revocation hearing without first balancing his interest in confronting an adverse witness against any proffered good cause for denying such […]

Jan 13, 2025

4th Circuit: Drug defendant’s sentence vacated a second time

Where a defendant who pleaded guilty to federal drug charges argued the drug quantity in the presentence report, or PSR, was based on unreliable information from informants, that he should […]

Aug 15, 2024

4th Circuit: Outburst gave judge right to change defendant’s sentence

The 4th Circuit holds that 18 U.S.C. § 3582 allows district courts to alter a sentence during the same hearing until it is unequivocally stated.

May 27, 2024

Convicted prosecutor avoids prison sentence

GREENBELT, Md. — A former Baltimore city prosecutor who achieved a national profile for charging police officers in a Black man’s death was spared prison time in her sentence for […]

Dec 22, 2017

Criminal Practice – Supervised Release – Continuation Post-Revocation – Successive Revocations – Maximum Sentence

United States v. Harris (Lawyers Weekly No. 001-001-18, 16 pp.) (Henry Floyd, J.) 16-4546; Dec. 19, 2017; USDC at Richmond, Va. (Robert Payne, S.J.) 4th Cir. Holding: Revocation of defendant‘s […]

Jun 10, 2015

Criminal Practice — No Third Chance for Supervised Release

U.S. v. Padgett (Lawyers Weekly No. 15-01-0577, 9 pp.) (Motz, J.) No. 14-4625, June 9, 2015; USDC at Huntington, W.Va. (Berger, J.) 4th Cir. Holding: A defendant originally convicted of […]

May 26, 2015

Criminal Practice — Longer Sentence Due to Prior Drug Crimes

U.S. v. Wynn (Lawyers Weekly No. 15-01-0531, 12 pp.) (Keenan, J.) No. 14-4599, May 20, 2015; USDC at Norfolk, Va. (Jackson, J.) 4th Cir. Holding: A district court did not […]