United States v. Cory Melvin, 978 F.3d 49

Melvin pleaded guilty over a decade earlier to a multi-count firearms indictment; sentenced in 2011 to 121 months and 3 years supervised release; released July 2017; supervised release began Nov. 28, 2017.
In Aug. 2019, with ~15 months left, Melvin moved under 18 U.S.C. § 3583(e)(1) for early termination, citing sustained law‑abiding behavior, steady employment, family stability, and that continued supervision was unnecessary.
The government opposed, characterizing Melvin’s record as mere compliance and arguing no exceptional or unforeseen circumstances justified early termination.
The District Court denied the motion, relying on non‑precedential Third Circuit language (Laine, Davies) that suggested early termination is appropriate only for "exceptional/extraordinary" or "new/unforeseen" circumstances; it found Melvin’s compliance insufficient.
On appeal, the Third Circuit held the District Court misapplied the legal standard: § 3583(e)(1) does not require exceptional or new circumstances, although such changes often justify early termination; the panel vacated and remanded for reconsideration under the correct standard and expedited the mandate because Melvin’s term was nearly expired.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3583(e)(1) requires "exceptional/extraordinary" or "new/unforeseen" circumstances to grant early termination	Melvin: statute does not demand extraordinary or new circumstances; court may grant based on conduct and interest of justice	Government: early termination should require exceptional or unforeseen circumstances; mere compliance is insufficient	Held: No categorical requirement; extraordinary/new circumstances may justify relief but are not necessary; district courts have broad discretion to consider wide range of factors
Whether the District Court’s reliance on Laine/Davies was an abuse of discretion warranting vacatur	Melvin: reliance on an incorrect legal standard tainted the analysis and warrants vacatur/remand	Government/District Court: even if standard referenced, factual weighing supported denial and court might reach same outcome	Held: Applying the wrong legal standard can be an abuse of discretion; vacated and remanded for reconsideration though district court may again deny under correct standard

United States v. Lussier, 104 F.3d 32 (2d Cir. 1997) (changed circumstances may justify modification of supervised‑release conditions)
United States v. Tomko, 562 F.3d 558 (3d Cir. 2009) (abuse of discretion occurs when a district court applies wrong legal standard)
United States v. Emmett, 749 F.3d 817 (9th Cir. 2014) (same: wrong legal standard on § 3583(e) is an abuse of discretion)
United States v. Parisi, 821 F.3d 343 (2d Cir. 2016) (Lussier does not require new/changed circumstances; recognizes they may justify modification)
United States v. Murray, 692 F.3d 273 (3d Cir. 2012) (extraordinary circumstances can justify early termination but are not necessary)
United States v. Smith, 445 F.3d 713 (3d Cir. 2006) (standard of review: abuse of discretion for denial of § 3583(e) motion)
United States v. Gammarano, 321 F.3d 311 (2d Cir. 2003) (a district court's statement that it considered § 3553(a) factors is sufficient)