United States v. Andrew Hulen, 879 F.3d 1015

Andrew Hulen was on five years’ supervised release following a 12‑month sentence for failing to register as a sex offender; one condition required participation in sex‑offender treatment.
Two months into release Hulen admitted numerous violations during mandatory treatment (e.g., drug use, sexual communications, contact with prohibited persons, lying to probation/treatment).
The treatment provider sent those admissions to Hulen’s probation officer and recommended termination from the program; probation filed a petition to revoke supervised release based on the admissions and the eventual termination.
Hulen moved to strike many alleged violations; the petition was narrowed to three violations: unauthorized employment, failure to pay a special assessment, and termination from treatment.
Hulen admitted the remaining violations; the district court revoked his supervised release and imposed imprisonment and a new term of supervised release.
Hulen appealed, arguing the use of his compelled admissions in the revocation proceeding violated his Fifth Amendment right against self‑incrimination.

Issue	Hulen's Argument	Government's Argument	Held
Whether admissions made during mandatory sex‑offender treatment could be used to revoke supervised release without violating the Fifth Amendment privilege against self‑incrimination	Use of his compelled admissions in the revocation proceeding violated his Fifth Amendment right	Fifth Amendment protects against use of compelled statements in criminal cases, but revocation proceedings are not criminal cases, so use was permissible	Revocation proceedings are not criminal cases for Fifth Amendment purposes; using Hulen’s admissions to revoke supervised release did not violate the Fifth Amendment

Morrissey v. Brewer, 408 U.S. 471 (revocation proceedings are not part of criminal prosecution; only basic due process required)
Minnesota v. Murphy, 465 U.S. 420 (revocation is not a criminal proceeding; privilege against self‑incrimination not available to probationer in revocation context)
Chavez v. Martinez, 538 U.S. 760 (Fifth Amendment protects against compelled testimony used in a criminal case)
Stoot v. City of Everett, 582 F.3d 910 (Fifth Amendment implicated only when compelled statements are used to initiate or support criminal prosecution)
United States v. Saechao, 418 F.3d 1073 (Fifth Amendment implicated where compelled statements were later used to charge a new crime)
United States v. Hall, 419 F.3d 980 (parole/probation/supervised‑release revocation hearings are constitutionally indistinguishable; Sixth Amendment rights limited)
Standlee v. Rhay, 557 F.2d 1303 (parole revocation is not part of criminal prosecution)
United States v. Hilger, 728 F.3d 947 (revocation permissible without corroboration required at trial)
United States v. Spangle, 626 F.3d 488 (Sixth Amendment right to self‑representation does not apply to revocation proceedings)
United States v. Verdin, 243 F.3d 1174 (appeal not moot where relief could affect length or conditions of supervised release)