United States v. Davis
1:19-cr-00154-MAC-CLS
| E.D. Tex. | Aug 11, 2023Background
- In October 2019 deputies stopped a Chrysler in Beaumont, Texas; search revealed over 400 grams of methamphetamine; driver Ryan Davis and passenger Erica Lang were arrested.
- Lang was indicted on conspiracy and possession-with-intent charges; she pleaded guilty to possession with intent and was sentenced to 37 months’ imprisonment and 3 years supervised release.
- Lang was released January 20, 2022 and began supervised release; her PSR documents a long history of substance abuse (marijuana, methamphetamine, cocaine).
- Supervision conditions require random urinalyses, substance-abuse treatment, and financial disclosure.
- Lang filed a pro se motion seeking early termination, citing completion of evaluation, negative urinalyses, stable housing, employment since February 2022, and payment of the special assessment.
- Probation confirmed compliance and low-risk status but recommended denial (no extraordinary circumstances; community interest); the Government opposed; the court denied Lang’s motion.
Issues
| Issue | Plaintiff's Argument (Gov't) | Defendant's Argument (Lang) | Held |
|---|---|---|---|
| Whether early termination of supervised release under 18 U.S.C. § 3583(e)(1) is warranted | Deny: continued supervision serves community interest; no extraordinary circumstances | Grant: consistent compliance, treatment complete, negative tests, stable life justify termination | Denied — court concluded §3553(a) factors and interests of justice do not warrant termination |
| Whether mere compliance and low-risk status suffice for early termination | No — compliance is expected and alone is insufficient | Yes — compliance and rehabilitation show supervision no longer needed | Denied — compliance without new/extraordinary change is inadequate |
| Whether defendant’s substance-abuse history supports continued supervision | Yes — long history of serious substance abuse and nature of offense favor continued oversight | No — treatment/evaluation clearance and negative tests show reduced risk | Court found history and offense seriousness weigh for continued supervision; denial affirmed |
Key Cases Cited
- United States v. Johnson, 529 U.S. 53 (establishes district court authority under 18 U.S.C. § 3583(e))
- United States v. Lussier, 104 F.3d 32 (2d Cir.) (early termination is "occasionally" justified; new circumstances often relevant)
- United States v. Melvin, 978 F.3d 49 (3d Cir.) (changed or unforeseen circumstances commonly support modification but are not strictly required)
- Parisi v. United States, 821 F.3d 343 (2d Cir.) (changed circumstances may justify supervised-release modification)
- United States v. George, 534 F. Supp. 3d 926 (N.D. Ill.) (early termination is not an entitlement; defendant bears burden)