United States v. Etheridge
2013 U.S. Dist. LEXIS 166494
| D.D.C. | 2013Background
- Etheridge pled guilty to conspiracy to possess with intent to distribute methamphetamine in a large-scale narcotics conspiracy (2001–2005).
- He began a five-year term of supervised release after release from prison and has now served four-fifths of that term.
- He filed a renewed motion on October 2013 seeking early termination or, alternatively, travel modification for employment.
- The Court had previously deny terminations and later modified domestic travel to accommodate business travel; renewal followed four years into supervision.
- At the hearing, the probation officer opposed termination due to offense seriousness but praised Etheridge’s extraordinary recovery and compliance.
- The Court granted early termination after weighing § 3553(a) factors, finding Etheridge’s conduct warranted termination and it was in the interest of justice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether early termination is warranted by the defendant's conduct | United States argues continued supervision is warranted by serious offense. | Etheridge contends exceptionally good post-release conduct justifies termination. | Yes; termination warranted by conduct. |
| Whether early termination is in the interest of justice | Government contends continued supervision serves public safety and deterrence given seriousness. | Termination serves rehabilitation and employment interests with minimal public risk. | Yes; termination in the interest of justice. |
Key Cases Cited
- United States v. Lussier, 104 F.3d 32 (2d Cir. 1997) (framework for considering § 3583(e)(1) in light of § 3553(a))
- United States v. McKay, 352 F. Supp. 2d 359 (E.D.N.Y. 2005) (full compliance not alone sufficient for early termination)
- United States v. Caruso, 241 F. Supp. 2d 466 (D.N.J. 2003) (extraordinary circumstances needed beyond compliance)
- United States v. Grimaldi, 482 F. Supp. 2d 248 (D. Conn. 2007) (progressive community reintegration supports early termination)
- United States v. King, 551 F. Supp. 2d 1298 (D. Utah 2008) (exceptional personal turnaround supports termination)
- United States v. Rentas, 573 F. Supp. 2d 801 (S.D.N.Y. 2008) (steady employment and stable life support termination)
- United States v. Harris, 689 F. Supp. 2d 692 (S.D.N.Y. 2010) (employment impact and travel considerations in determining justice)