United States v. Aaron Wyatt
20-3208
| 7th Cir. | Jun 8, 2021Background:
- Aaron Wyatt was previously sentenced to 264 months for distributing crack cocaine; his supervised release had been revoked once before and he received 12 months.
- Five months after completing that term, Wyatt tested positive for methamphetamine and admitted possessing marijuana and methamphetamine while on supervised release.
- Based on those admissions (Grade B violations), the district court revoked supervised release and sentenced Wyatt to 18 months' imprisonment followed by 24 months' supervised release.
- Wyatt appealed; his appointed counsel moved to withdraw under Anders v. California, arguing the appeal is frivolous; Wyatt did not respond or indicate whether he wished to challenge his admissions.
- The Seventh Circuit reviewed the limited issues raised by counsel, found the admissions knowing and voluntary, and determined challenges to revocation, Guidelines calculation, and sentence reasonableness were without merit.
- The court granted counsel’s motion to withdraw and dismissed the appeal, and noted ineffectiveness claims are better raised on collateral review.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether revocation was improper | Government: revocation required because Wyatt admitted possession of controlled substances | Wyatt: could challenge revocation | Frivolous — admission and statutory basis for revocation established |
| Whether Guidelines imprisonment range was miscalculated | Government: court correctly applied Chapter 7 policy statements and CHC VI | Wyatt: could contest range computation | No reversible error; range properly computed (21–27 months) |
| Whether 18-month sentence was substantively unreasonable | Government: sentence reasonable and below Guidelines | Wyatt: sentence excessive/unreasonable | Reasonable — court considered §3553(a) factors and imposed below-guidelines term |
| Whether counsel was ineffective at revocation hearing | Government: ineffective-assistance claims belong on collateral review | Wyatt: counsel ineffective | Not addressed on direct appeal; such claims are best raised in collateral proceedings |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for counsel withdrawal when appeal is frivolous)
- Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (no unqualified right to counsel at supervised-release revocation)
- United States v. Wheeler, 814 F.3d 856 (7th Cir. 2016) (Seventh Circuit follows Anders safeguards in revocation appeals)
- United States v. Jones, 774 F.3d 399 (7th Cir. 2014) (revocation required upon finding possession of a controlled substance)
- United States v. Peterson, 852 F.3d 629 (7th Cir. 2017) (below-Guidelines revocation sentences are presumed reasonable)
- Massaro v. United States, 538 U.S. 500 (U.S. 2003) (ineffective-assistance claims normally raised on collateral review)
- United States v. Konczak, 683 F.3d 348 (7th Cir. 2012) (counsel should inform court whether client wishes to challenge admissions on appeal)
- United States v. Cates, 950 F.3d 453 (7th Cir. 2020) (discussing appropriate forum for ineffective-assistance claims)