United States v. Ashley Brumfield
708 F. App'x 116
| 4th Cir. | 2018Background
- Ashley Nicole Brumfield had two separate supervised-release terms from federal drug convictions (2010 and 2012).
- Probation filed a petition to revoke both supervised-release terms; district court imposed concurrent 10-month imprisonment terms after revocation.
- Brumfield appealed, raising two principal challenges: (1) that the 2010 supervised-release term had expired before the revocation petition was filed, depriving the district court of jurisdiction; and (2) that the district court violated Tapia by basing sentencing on rehabilitative concerns.
- The Government conceded the lack of jurisdiction regarding the 2010 revocation petition but contested the challenge to the 2012 revocation and the Tapia-related claim.
- The court reviewed Brumfield’s arguments under the plain-error standard because they were raised for the first time on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court had jurisdiction to revoke 2010 supervised release | Brumfield: petition filed after term expired, so no jurisdiction | Government: (conceded) court had no jurisdiction | Reversed: no jurisdiction to revoke 2010 term |
| Whether Tapia v. United States was violated by sentencing | Brumfield: court improperly relied on rehabilitative goals in sentencing | Government: no plain error; sentencing lawful | No plain error found as to Tapia claim for 2012 case |
| Whether revocation and 10-month sentence for 2012 term were proper | Brumfield: challenges sentencing procedure | Government: revocation and sentence proper | Affirmed: revocation and 10-month sentence for 2012 case upheld |
| Standard of review applicable to newly raised claims on appeal | Brumfield: applies plain-error review | Government: concurs on standard | Court applied plain-error review |
Key Cases Cited
- Tapia v. United States, 564 U.S. 319 (2011) (limits on imposing imprisonment to promote rehabilitation)
- United States v. McNeal, 818 F.3d 141 (4th Cir.) (plain-error review for issues raised first on appeal)
- United States v. Mills, 850 F.3d 693 (4th Cir.) (elements of plain-error review)
- Molina-Martinez v. United States, 136 S. Ct. 1338 (2016) (when to correct plain error affecting fairness, integrity, or public reputation of proceedings)