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United States v. Hobson
2:25-cr-00029
E.D. Wis.
May 19, 2025
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Background

  • 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.
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Case Details

Case Name: United States v. Hobson
Court Name: District Court, E.D. Wisconsin
Date Published: May 19, 2025
Docket Number: 2:25-cr-00029
Court Abbreviation: E.D. Wis.