United States v. Edgardo Esteras, 88 F.4th 1163

Edgardo Esteras was sentenced in 2018 for heroin distribution, receiving 12 months in prison (consecutive to a prior federal conviction’s sentence), followed by six years of supervised release.
His supervised release began in January 2020. In 2023, a probation officer alleged Esteras violated release conditions by domestic violence, aggravated menacing, criminal damaging, and firearm possession (charges were later dismissed at the victim’s request).
The district court found Esteras had possessed a firearm while on supervision and imposed a 24-month prison sentence (double the advised range), adding three more years of supervised release with additional conditions.
Esteras objected to the district court’s consideration of factors under 18 U.S.C. § 3553(a)(2)(A) (seriousness, respect for law, just punishment) in determining his revocation sentence.
On appeal, Esteras argued consideration of these factors amounted to procedural error; the government argued it was permissible under controlling precedent.

Issue	Esteras's Argument	Government's Argument	Held
Whether the district court erred by considering certain § 3553(a)(2)(A) factors in revoking supervised release	Court may not consider seriousness, respect for law, or just punishment under § 3553(a)(2)(A) when imposing a revocation sentence	Consideration of those factors is not forbidden; district court has discretion under precedent	Consideration of those factors is allowed; district court did not err

United States v. Lewis, 498 F.3d 393 (6th Cir. 2007) (district courts have discretion to consider, but are not required to exclude, § 3553(a)(2)(A) factors in supervised release decisions; controlling precedent)
Johnson v. United States, 529 U.S. 694 (2000) (revocation of supervised release may promote respect for law, not just punishment)
United States v. Johnson, 640 F.3d 195 (6th Cir. 2011) (remedy for violation must correspond to the breach of court’s trust embodied by the original sentence)