United States v. Darrell Taylor, 747 F.3d 516

Taylor pled guilty in 2007 to possession with intent to distribute cocaine base and was sentenced to 60 months' imprisonment with four years of supervised release.
His first term of supervised release began in May 2011; he violated conditions in the following year and admitted the violations at revocation hearings, receiving 6 months' imprisonment and 18 more months of supervised release.
Taylor began a second term of supervised release on May 29, 2013; shortly thereafter he allegedly assaulted his girlfriend, leading to subsequent police involvement and state charges.
Federal authorities issued a warrant for Taylor’s arrest on July 26, 2013 and executed it on August 5, 2013, charging multiple violations of supervised release including delinquent reports and failure to attend testing.
At the final revocation hearing, Taylor admitted all charged violations except domestic assault; the court allowed him to speak and consider evidence related to the four release conditions.
The district court imposed a 10-month prison sentence followed by 13 months of supervised release, with domestic violence and anger management counseling requirements; Taylor contested the lack of a personal admission colloquy and the substantive reasonableness of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was plain error from lack of direct admission.	Taylor asserts district court erred by not asking him personally to admit violations.	Taylor's waiver was knowingly voluntary; counsel admissions in presence were adequate.	No plain error; waiver valid despite no direct colloquy.
Whether the sentence was substantively reasonable.	Taylor contends the court improperly weighed the assault-related evidence and imposed excessive punishment.	Court properly considered relevant factors and within guideline range; presumption of reasonableness applies.	Sentence presumed substantively reasonable within guideline range.

United States v. Tapia-Escalera, 356 F.3d 181 (1st Cir. 2004) (waiver of rights at revocation based on prior familiarity)
United States v. Farrell, 393 F.3d 498 (4th Cir. 2004) (waiver valid when counsel admitted violations in defendant's presence)
United States v. Rapert, 813 F.2d 182 (8th Cir. 1987) (guilty-plea rules not required at revocation hearings)
United States v. Correa-Torres, 326 F.3d 18 (1st Cir. 2003) (waiver must be knowingly and voluntarily made)
United States v. Taylor, 679 F.3d 1005 (8th Cir. 2012) (plain-error standard for revocation proceedings)
United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (presumption of reasonableness for within-range sentences)