Jeffrey H. Hunt v. United States, 109 A.3d 620

Jeffrey Hunt, a D.C. parolee supervised by CSOSA, was charged and convicted after a bench trial for intentionally removing a GPS monitoring device, in violation of D.C. Code § 22-1211(a)(1)(A).
CSO Mili Patel testified she placed Hunt on GPS in 2012 as a "graduated sanction" for noncompliance, and specifically said the GPS was not a condition of his release.
The statute criminalizes intentionally removing a device that a person is "required to wear . . . as a condition of . . . parole." Hunt conceded removal and that the device was a qualifying "device;" he argued the government failed to prove the GPS was a parole condition.
The trial court found Hunt was legally required to wear the GPS based on a sanction-based agreement and concluded the statute did not require a court-ordered condition.
The D.C. statute/regulatory framework distinguishes conditions imposed by USPC or the Superior Court from CSOSA-imposed administrative sanctions; CSOSA lacks authority to impose release conditions and instead may apply sanctions to encourage compliance.
The Court of Appeals reversed, holding the evidence showed GPS was a sanction, not a parole condition, and thus did not satisfy § 22-1211(a)(1)(A); it remanded with instructions to enter judgment of acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a GPS imposed by CSOSA as an administrative sanction qualifies as being "required to wear . . . as a condition of parole" under D.C. Code § 22-1211(a)(1)(A)	Hunt: Gov't failed to show GPS was a parole condition; it was a sanction	Government/Trial court: GPS was "required" and statutory language does not require a court order; a CSO-imposed requirement suffices	Court: Reversed — GPS imposed as a CSOSA sanction is not a "condition" of parole under the statute

Tippett v. Daly, 10 A.3d 1123 (2010) (standard of de novo review for statutory interpretation)
Dobyns v. United States, 30 A.3d 155 (2011) (courts should apply established legal meanings of borrowed terms of art)
Joiner-Die v. United States, 899 A.2d 762 (2006) (standard for viewing evidence in sufficiency challenges)
Burks v. United States, 437 U.S. 1 (1978) (directed acquittal required when conviction is reversed for insufficient evidence)
Ruffin v. United States, 76 A.3d 845 (2013) (application of rule of lenity in construing criminal statutes)
United States v. Hilton, 701 F.3d 959 (2012) (discussion of strict construction of criminal statutes)
Morissette v. United States, 342 U.S. 246 (1952) (legislative borrowing of legal terms brings associated meanings)