United States v. Feroz Siddiqui, 698 F. App'x 118

Background

Siddiqui was before the district court on allegations he violated conditions of supervised release by failing to attend mental health treatment.
At the revocation hearing Siddiqui admitted the violation and agreed to a sentence of 10 months’ imprisonment and termination of supervised release.
He later appealed, arguing procedural errors under Federal Rule of Criminal Procedure 32.1(b) (lack of written notice and opportunity to speak) and that the court failed to consider applicable sentencing factors, Guidelines policy statement, and to explain the sentence under 18 U.S.C. §§ 3553(a), 3583(e).
The Fourth Circuit reviewed the revocation for abuse of discretion but applied plain-error review to Siddiqui’s claims because he admitted the violation and accepted the 10-month sentence.
The court held Siddiqui did not show prejudice from any procedural defects and, even assuming plain error, declined to correct the errors because Siddiqui accepted the negotiated outcome and remand could undermine that acceptance.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Siddiqui was entitled to written notice of the alleged violation before revocation	Siddiqui argued he did not receive written notice that he failed to attend treatment, violating Rule 32.1(b) and due process	Government pointed out Siddiqui admitted the violation at the hearing and accepted the sentence	Court held no prejudice shown; admission foreclosed reversal under plain-error review
Whether Siddiqui (or counsel) was entitled to make a statement before sentencing	Siddiqui argued he and counsel lacked opportunity to speak in mitigation as required by Rule 32.1(b)	Government noted neither Siddiqui nor counsel sought to speak and Siddiqui accepted the disposition	Court found no plain error; absence of a clear directive meant issue not plainly established
Whether the court failed to consider sentencing factors, Guidelines policy statement, or explain the sentence	Siddiqui contended the court didn’t address §§ 3553(a), 3583(e), or the applicable Guidelines range and did not adequately explain the sentence	Government maintained the agreed sentence was within permissible range and Siddiqui did not show a reasonable probability of a different outcome	Court held Siddiqui failed to show the sentence was outside the policy statement range or that his substantial rights were affected
Whether any errors warrant remand despite plain-error standard	Siddiqui sought a new revocation hearing/remand to correct procedural defects	Government argued Siddiqui accepted a beneficial 10-month term instead of risking a Grade A violation and longer sentence; remand could undermine that acceptance	Court exercised discretion to affirm, concluding correction not warranted because remand would undermine the negotiated resolution

Key Cases Cited

United States v. Pregent, 190 F.3d 279 (4th Cir. 1999) (standard of review for supervised-release revocation)
United States v. Copley, 978 F.2d 829 (4th Cir. 1992) (due process protections apply to supervised-release revocation)
Morrissey v. Brewer, 408 U.S. 471 (1972) (minimum due process requirements for probation revocation)
United States v. Lemon, 777 F.3d 170 (4th Cir. 2015) (plain-error framework and discretionary correction of errors)
United States v. Godwin, 272 F.3d 659 (4th Cir. 2001) (defendant bears burden to show error affected substantial rights)
United States v. Olano, 507 U.S. 725 (1993) (definition and consequences of plain error)
United States v. White, 836 F.3d 437 (4th Cir. 2016) (prejudice inquiry under plain-error review requires reasonable probability of a different outcome)
United States v. Wynn, 684 F.3d 473 (4th Cir. 2012) (absence of controlling precedent can preclude finding of plain error)