Esteras v. United States, 606 U.S. 185

Edgardo Esteras was convicted of conspiring to distribute heroin, sentenced to 12 months in prison and 6 years of supervised release.
While on supervised release, Esteras was arrested for alleged domestic violence and other crimes, leading to revocation proceedings.
The district court revoked his supervised release, imposing 24 months of reimprisonment, referencing the need to "promote respect for the law" under 18 U.S.C. §3553(a)(2)(A).
The Sixth Circuit affirmed, holding that courts may consider retribution (§3553(a)(2)(A)) when revoking supervised release.
The Supreme Court granted certiorari to resolve a circuit split about whether §3553(a)(2)(A) may be considered during revocation of supervised release terms.

Issue	Esteras's Argument	Government's Argument	Held
Can district courts consider §3553(a)(2)(A) (retribution) when revoking supervised release?	No, Congress omitted this factor from §3583(e), so it cannot be considered.	Yes, omission means courts are not required to consider it, but can do so at their discretion.	No, district courts may not consider §3553(a)(2)(A) in revocation decisions.
Does the omission of certain §3553(a) factors in §3583(e) create an exclusive list of what can be considered in revocation?	Yes, expressio unius est exclusio alterius applies, excluding omitted factors.	No, the list is mandatory for consideration but does not bar consideration of other factors.	The statute’s list is exhaustive; omitted factors may not be considered.
Is considering the "seriousness of the offense" or "promoting respect for the law" inherently part of revocation decisions?	It is not, since only forward-looking factors like deterrence, incapacitation, and rehabilitation are permitted.	It is inherent and often overlaps with permitted factors like deterrence.	Only forward-looking factors (not retribution for original offense) may be considered.
How should appellate courts review claims of impermissible reliance on §3553(a)(2)(A)?	Objection at trial is needed for de novo review; otherwise, plain-error review applies.	Should be difficult to enforce, given overlap in factors and language used.	Defendants must preserve objections; plain-error review for unpreserved claims.

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (Supreme Court precedent on syllabi not constituting part of the opinion)
United States v. Granderson, 511 U.S. 39 (Supervised release is not punishment in lieu of incarceration)
United States v. Johnson, 529 U.S. 53 (Supervised release’s rehabilitative role)
Tapia v. United States, 564 U.S. 319 (Courts may not consider retribution when imposing supervised release)
Concepcion v. United States, 597 U.S. 481 (Express preclusion of retribution considerations for supervised release)
Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (Expressio unius est exclusio alterius canon explained)
United States v. Olano, 507 U.S. 725 (Standard for plain error review)