United States v. GIBSON, 2:06-cr-00243

Lamar Gibson was convicted of possession with intent to distribute crack cocaine and sentenced to 162 months’ imprisonment plus a 5‑year term of supervised release; he began supervision on July 19, 2018 and has served about three‑quarters of the term.
Gibson says he was prescribed medical marijuana by a physician and registered in Pennsylvania’s Medical Marijuana Program on December 10, 2020; he did not attach medical records to his motion.
Gibson tested positive for marijuana in April and May 2021 (following family deaths) and seeks either permission to use state‑authorized medical marijuana while on federal supervised release or, alternatively, early termination of supervised release.
The United States opposes allowing marijuana use, asserting federal law prohibits possession/use and supervised‑release conditions require compliance with federal law; it also opposes early termination.
The court previously denied Gibson’s 2020 early‑termination motion without prejudice; the Third Circuit’s decision in United States v. Melvin (issued after that denial) supplies the controlling guidance on § 3583(e) motions.
The court denied Gibson’s current motion: it held it cannot authorize conduct that violates federal law (marijuana possession), and after weighing § 3553(a) factors under Melvin, found early termination is not warranted or in the interest of justice on the record presented.

Issue	Plaintiff's Argument (United States)	Defendant's Argument (Gibson)	Held
Whether the court may permit Gibson to use medical marijuana while on federal supervised release	Federal law classifies marijuana as a Schedule I drug; possession/use (except limited FDA research exception) is a federal crime and supervised‑release conditions require compliance with federal law, so the court cannot authorize violation	Gibson is prescribed and registered under Pennsylvania’s medical marijuana program and needs marijuana for anxiety and hypertension	Denied — court cannot permit marijuana use because federal law preempts state law and possession remains unlawful under federal law
Whether Gibson’s supervised release should be terminated early under 18 U.S.C. § 3583(e)	Supervision protects the public; Gibson committed a serious offense, received a large downward variance, and terminating supervision before the statutory minimum could create unwarranted disparities	Gibson has complied with release conditions overall, runs businesses and community programs, and argues low risk of reoffense; he requests termination so he may lawfully use medical marijuana under state law	Denied — after considering § 3553(a) factors (nature of offense, need for deterrence/protection, guideline and statutory ranges, disparities), the factors are neutral or weigh against termination and early termination is not in the interest of justice on this record

Gonzales v. Raich, 545 U.S. 1 (2005) (holding federal Controlled Substances Act criminalizes marijuana possession despite state laws permitting medical use)
United States v. Melvin, 978 F.3d 49 (3d Cir. 2020) (clarifying discretionary standard and § 3553(a) consideration for early termination of supervised release under § 3583(e))
Pepper v. United States, 562 U.S. 476 (2011) (explaining supervised release serves rehabilitative ends distinct from incarceration)
United States v. Johnson, 529 U.S. 53 (2000) (describing supervised release’s rehabilitative purpose)