United States v. DeRon Edwards Robinson, 63 F.4th 530

DeRon Robinson was stopped by a Hendersonville, TN officer for an alleged tinted-window violation; the officer extended the stop and (according to Robinson) suggested a chance of stopping a criminal.
Robinson told the officer he had a gun in the glove compartment; the officer then searched the car and found a loaded handgun, marijuana, cocaine, and prescription pills.
State and federal prosecutors declined to indict (district court found likely due to obvious Fourth Amendment problems), but a probation officer petitioned to revoke Robinson’s supervised release.
Robinson moved to suppress the evidence at the revocation hearing and separately demanded a jury trial under Haymond; the government conceded a Fourth Amendment violation but opposed suppression at the revocation hearing and opposed a jury right.
The district court denied suppression (held the exclusionary rule does not apply to supervised-release revocations), refused the jury demand, found Robinson violated release conditions, revoked supervised release, and sentenced him to 28 months’ imprisonment.
On appeal the Sixth Circuit affirmed: the exclusionary rule does not bar evidence at supervised-release revocation hearings (following Scott), and Haymond does not require a jury for §3583(g)-based revocations.

Issue	Plaintiff's Argument (Robinson)	Defendant's Argument (United States)	Held
Whether the exclusionary rule bars illegally obtained evidence at a supervised-release revocation hearing	Exclude evidence because it was obtained in violation of the Fourth Amendment and the rule should extend to revocation hearings	Scott and related precedent show the exclusionary rule is a judge-made remedy reserved for criminal trials and parole revocations; supervised release is analogous and exclusion would harm supervision and deterrence calculus	Denied — exclusionary rule does not apply to supervised-release revocation hearings; court follows Scott and related Supreme Court/utilitarian precedents
Whether Haymond requires a jury trial for revocation under 18 U.S.C. §3583(g)	Haymond’s reasoning extends to §3583(g): judicial fact-finding increased punishment and thus triggers the Sixth Amendment jury right	Haymond was limited to §3583(k); Justice Breyer’s controlling concurrence is narrower and focuses on §3583(k)’s unique features, which §3583(g) lacks	Denied — Haymond does not render §3583(g) unconstitutional; no jury right for §3583(g) revocations under controlling Haymond reasoning

Pa. Bd. of Prob. & Parole v. Scott, 524 U.S. 357 (1998) (exclusionary rule does not compel exclusion at parole-revocation hearings)
United States v. Haymond, 139 S. Ct. 2369 (2019) (plurality and Breyer concurrence holding §3583(k) unconstitutional; Breyer’s concurrence is the controlling, narrow basis)
Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule is a judge-made remedy evaluated by deterrence-cost analysis)
Hudson v. Michigan, 547 U.S. 586 (2006) (refusing to extend the exclusionary rule to all Fourth Amendment violations)
United States v. Calandra, 414 U.S. 338 (1974) (no exclusionary rule in grand-jury proceedings)
Janis v. United States, 428 U.S. 433 (1976) (no exclusionary rule in civil tax proceedings)
INS v. Lopez-Mendoza, 468 U.S. 1032 (1984) (no exclusionary rule in deportation proceedings)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (jury required for facts that increase statutory maximum)
Alleyne v. United States, 570 U.S. 99 (2013) (jury required for facts that increase mandatory minimum)
Marks v. United States, 430 U.S. 188 (1977) (narrowest-grounds rule for identifying controlling Supreme Court precedent)