United States v. Harris
258 F. Supp. 3d 137
| D.D.C. | 2017Background
- Lamar Harris was convicted in 1989 as a major participant in a violent, large-scale cocaine distribution ring; convictions included use of a juvenile and multiple firearms offenses.
- Original sentence included concurrent life terms plus additional consecutive mandatory terms; convictions and sentences were later reduced by appeals, habeas petitions, and § 3582 relief to 325 months imprisonment.
- Harris completed his federal prison term in December 2012 and has served ~4 years, 7 months of a statutorily mandated 10-year (120-month) supervised release term.
- Since release he has remained infraction-free on supervision, completed halfway house placement, maintained full-time employment (with promotion), married, and participated in community and family activities; probation officer ultimately recommended continued supervision but acknowledged Harris’s positive progress.
- Harris moved under 18 U.S.C. § 3583(e)(1) for early termination of supervised release; the government opposed, citing the gravity and violence of the original offenses and risks of recidivism.
- The Court granted the motion, reducing supervised release from 120 to 60 months, concluding Harris’s conduct and the interests of justice warranted the reduction after considering § 3553(a) factors.
Issues
| Issue | Government's Argument | Harris's Argument | Held |
|---|---|---|---|
| Whether a district court may terminate or reduce a statutorily mandated pre-2002 term of supervised release under 18 U.S.C. § 3583(e)(1) | District court retains discretion to consider § 3583(e)(1) relief; 2002 amendment not retroactively stripping authority (gov't disputed breadth but accepted district discretion here) | § 3583(e)(1) applies and authorizes termination of pre-2002 mandatory supervised release terms | Court treated § 3583(e)(1) as available and applied it to Harris’s pre-2002 mandatory term (granted reduction) |
| Whether early termination is warranted under § 3583(e)(1) after considering pertinent § 3553(a) factors and the "interest of justice" | Opposition: severity of prior violent conduct and community harm, minimal supervision now, and general risk of recidivism weigh against early termination; suggested a high bar (changed circumstances/exceptional behavior) | Harris: sustained compliance, rehabilitation, stable employment/family life, positive community involvement, probation officer’s non-opposition, and minimal ongoing need for supervision | Court found Harris’s post-release conduct, low recidivism risk indicators, rehabilitation, and the interest of justice supported reducing supervised release from 120 to 60 months |
Key Cases Cited
- United States v. Harris, 959 F.2d 246 (D.C. Cir.) (describing defendant’s role in the violent drug ring)
- United States v. Epps, 707 F.3d 337 (D.C. Cir. 2013) (addressing interplay of § 3583 and pre-2002 § 841 supervised-release provisions and leaving district court authority question to be resolved below)
- United States v. Johnson, 529 U.S. 694 (2000) (discussing supervised release purpose and availability of § 3583(e)(1) relief)
- United States v. Mathis-Gardner, 783 F.3d 1286 (D.C. Cir. 2015) (remanding where district court did not explain consideration of § 3553(a) factors in denying early-termination motion)
- United States v. Lussier, 104 F.3d 32 (2d Cir. 1996) (framing "occasionally, changed circumstances—for instance, exceptionally good behavior" standard for § 3583(e)(1) relief)
- United States v. Spinelle, 41 F.3d 1056 (6th Cir. 1994) (permitting § 3583(e)(1) relief for statutorily required supervised-release terms in some contexts)
- United States v. Vargas, 564 F.3d 618 (2d Cir. 2009) (discussing district court authority over supervised-release terms imposed under statute)
- United States v. Parker, 219 F. Supp. 3d 183 (D.D.C. 2016) (granting early termination where rehabilitation and changed sentencing context supported reduction)