United States v. Janis Kreitinger, 710 F. App'x 269

Janis Kreitinger, originally sentenced in 2007 for aggravated identity theft and credit-card fraud, received 48 months prison and three years supervised release.
First supervised release (2015): while at a court-ordered residential reentry center she repeatedly violated center rules; after earlier warnings and an opportunity to conform, the court revoked release once and imposed seven months imprisonment plus 1 year supervised release and a 180-day reentry-center condition.
Second supervised release began May 13, 2016; within three months the U.S. Probation Office filed a second revocation petition for new violations.
District court found Kreitinger committed multiple violations: possession of contraband at the center (food stamp card, debit card, outside bedding), attempted theft of chemical bottles, making false statements to staff (lying about the bottles and smoking permission), and attempting to correspond with a felon in federal prison.
The court concluded these acts reflected a persistent unwillingness to comply with supervision conditions, revoked her supervised release, and sentenced her to six months imprisonment plus one year of supervision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation was justified given only ‘‘technical’’ violations	Kreitinger: violations were minor technical breaches insufficient to warrant revocation	Government/District Court: violations showed persistent, pervasive unwillingness to comply with conditions, not mere technical breaches	Affirmed: revocation within court’s discretion because conduct showed stubborn refusal to comply
Whether court improperly relied on accumulation of technical violations	Kreitinger: district court reflexively punished an accumulation of minor infractions	Court: made reasoned finding of ongoing noncompliance tied to a special condition to follow facility rules	Affirmed: no abuse of discretion; court did not act reflexively
Whether additional conduct (attempt to correspond with felon) affected revocation analysis	Kreitinger: (implicitly) downplayed significance of correspondence	Government: correspondence was a separate violation supporting revocation	Affirmed: separate violation reinforced decision to revoke
Whether appellant preserved a challenge to the substantive reasonableness of the revocation sentence	Kreitinger: did not raise substantive-reasonableness arguments on appeal	Government: argued appeal might include sentence challenge	Court: treated sentence challenge as waived	Affirmed: sentence-reasonableness issue waived by failure to brief it

United States v. Melton, 666 F.3d 513 (8th Cir. 2012) (standard for abuse-of-discretion review of supervised-release revocation)
United States v. Young, 756 F.2d 64 (8th Cir. 1985) (revocation inappropriate for mere accumulation of technical violations)
United States v. Reed, 573 F.2d 1020 (8th Cir. 1978) (condemning reflexive revocations based solely on technical violations)
United States v. Burkhalter, 588 F.3d 604 (8th Cir. 2009) (persistent, pervasive unwillingness to comply may warrant revocation)
United States v. Kimball, 830 F.3d 747 (8th Cir. 2016) (similar principle regarding reentry-center noncompliance)
United States v. Azure, 539 F.3d 904 (8th Cir. 2008) (issue-waiver rule for failure to brief sentencing challenges)