United States v. Christopher Zoukis, 22-6263

Appellant Christopher Hardy Zoukis pled guilty in 2007 to possessing and receiving child pornography while on state probation for a prior offense.
Zoukis was sentenced in 2008 to 151 months in prison and 6 years of supervised release.
After serving his prison term, his supervised release began in October 2018.
In March 2021, Zoukis filed a motion for early termination of his supervised release after serving about 2.5 years of the 6-year term.
The government initially objected but withdrew its objection after Zoukis passed a polygraph.
The district court denied the motion without prejudice, acknowledging Zoukis's rehabilitation but finding early termination unwarranted at this time.

Issue	Zoukis's Argument	Government's Argument	Held
Whether early termination of supervised release was proper	Had demonstrated good conduct and rehabilitation	Factors under § 3553(a) weighed against early release	District court did not abuse discretion in denying termination

United States v. Pregent, 190 F.3d 279 (4th Cir. 1999) (denial of early termination of supervised release reviewed for abuse of discretion)