United States v. Brock Campbell, 681 F. App'x 202

Campbell challenged district court revocation of supervised release, 10-month prison term, and nine-month halfway-house requirement.
He argued due process was violated by the court’s reliance on hearsay at sentencing.
He also challenged the nine-month halfway-house condition as an abuse of discretion.
At revocation, an officer testified about Campbell’s drug dealing based on informant information gathered before a search warrant.
A white substance seized from Campbell’s bedroom and his admissions about drug use supported the findings of resumed drug dealing.
The court allowed cross-examination and concluded the hearsay testimony was sufficiently reliable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hearsay used at sentencing violated due process	Campbell argues due process was violated by uncorroborated hearsay.	Campbell contends the district court erred in relying on hearsay for sentence.	No due process violation; information had reliability indicia and was permissible for sentencing.
Whether the nine-month halfway-house condition was an abuse of discretion	Campbell claims the condition is unnecessarily restrictive and unwarranted.	The district court reasonably tied the condition to § 3583(d) factors and Campbell’s history.	No abuse of discretion; partial confinement reasonably related to deterrence, treatment, and public protection.

United States v. Powell, 650 F.3d 388 (4th Cir. 2011) (hearsay can be used if reliable enough for accuracy in sentencing)
United States v. Faulls, 821 F.3d 502 (4th Cir. 2016) (review of special conditions for abuse of discretion)
United States v. Marino, 833 F.3d 1 (1st Cir. 2016) (district court may impose community confinement as a condition)
United States v. Henry, 819 F.3d 856 (6th Cir. 2016) (halfway house term may comply with § 3583(d)(2))