United States v. Hobson
2:25-cr-00029
E.D. Wis.May 19, 2025Background
- Darrell Tyler was indicted on three counts: Hobbs Act robbery, brandishing a firearm during a crime of violence, and possession of a firearm by a felon.
- Tyler was detained pending trial following a recommendation from Pretrial Services and a hearing, despite arguing for release with conditions.
- Tyler then filed a motion to vacate the detention order and requested release with conditions.
- The government opposed the motion, and the court analyzed whether Tyler's motion was to reopen the hearing or to appeal the detention order.
- The court treated the motion as one to reopen the detention hearing under 18 U.S.C. § 3142(f), which requires new, material information not previously available.
- The court found no new material information was presented and denied the motion to vacate the detention order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detention pending trial remains warranted | Tyler poses flight risk and danger | Sufficient conditions could assure appearance and safety | Detention order remains; motion denied |
| Whether new material information exists to reopen | None presented | Motion implied new circumstances | No new information; no basis to reconsider |
| Proper legal standard for reviewing detention | Review per § 3142(f) | Unclear; possibly sought district review | Applied § 3142(f) standard |
| Burden of proof for rebutting presumption | Detention presumption applies | Tyler’s community/family ties rebut presumption | Defendant rebutted presumption, but other factors support detention |
Key Cases Cited
- No key cases with official reporter citations were cited in the opinion.
