United States v. Jade Stauffer, 22-2476

Stauffer pleaded guilty in the Middle District of Pennsylvania to misappropriation of postal funds (18 U.S.C. § 1711) and was sentenced to 2 years probation and $4,626.01 restitution, payable $100/month.
Probation supervision was transferred to the Northern District of New York (Binghamton).
While on probation Stauffer admitted multiple violations: failure to pay restitution, leaving the district without permission, failure to notify probation of changes in residence/employment, failure to notify probation of contact with law enforcement after a car accident that resulted in a motorcyclist’s death, and failure to pay financial penalties.
The district court revoked probation, imposed 3 months’ imprisonment followed by 12 months’ supervised release, after considering § 3553(a) factors and mitigating information (mental health, finances, employment, housing).
Stauffer appealed, arguing the 12‑month supervised‑release term was substantively unreasonable and that further supervision by the same probation officer was improper.
The Second Circuit affirmed the district court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a 12‑month supervised‑release term following 3 months’ imprisonment is substantively unreasonable	Gov’t: sentence falls within permissible range and district court weighed §3553(a) factors	Stauffer: 12 months is substantively unreasonable given mitigating circumstances	Affirmed — sentence within permissible range; not an abuse of discretion
Whether further supervision by the same probation officer is unreasonable	Gov’t: court addressed concerns and instructed counsel to report problems	Stauffer: continued supervision by same officer is substantively unreasonable	Affirmed — district court appropriately handled concerns; no abuse of discretion

United States v. Broxmeyer, 699 F.3d 265 (2d Cir. 2012) (establishes deferential abuse‑of‑discretion standard for sentence‑reasonableness review)
United States v. Bonilla, 618 F.3d 102 (2d Cir. 2010) (sentence is acceptable if within the range of permissible decisions)
United States v. Bleau, 930 F.3d 35 (2d Cir. 2019) (substantive unreasonableness occurs when sentence is shockingly high or low or legally unsupportable)
United States v. Lifshitz, 714 F.3d 146 (2d Cir. 2013) (affirming supervised‑release where defendant had patterns of noncompliance)