United States v. John Badgett, 19-10146

Badgett pleaded guilty in 2009 to six counts of armed bank robbery and received six concurrent 108-month prison terms followed by six concurrent five-year terms of supervised release.
Released in 2015; supervised-release jurisdiction transferred to the Northern District of Texas in 2016.
In 2018 probation reported violations: alcohol in a vehicle, absconding to Alaska without permission, and failing to report for a mandatory drug test.
Probation calculated an advisory revocation range of 5–11 months per count but noted 18 U.S.C. § 3583(g) makes imprisonment mandatory for certain drug- and firearm-related supervised-release violations.
At the revocation hearing Badgett admitted the violations; the district court revoked release and imposed consecutive 8‑month sentences on each of the six terms (48 months total).
On appeal Badgett argued (1) § 3583(g) is unconstitutional under United States v. Haymond, and (2) the 48‑month aggregate revocation sentence was substantively unreasonable.

Issue	Badgett's Argument	Government's Argument	Held
Whether § 3583(g)’s mandatory-imprisonment rule violates Fifth/Sixth Amendment under Haymond	§ 3583(g) shares Haymond’s defects (targets specified conduct; removes judicial discretion), so it is unconstitutional	Haymond was not extended to § 3583(g); no clear precedent made application plain error; some §3583(g) triggers cover noncriminal conduct	Rejected on plain-error review — no clear or obvious error; prior caselaw did not extend Haymond to §3583(g); Badgett’s guilty admissions preclude prejudice showing
Whether the 48‑month consecutive revocation sentence was substantively unreasonable	Sentence was greater than necessary given non‑criminal nature of Alaska conduct and rehabilitation efforts	Sentence was within each Guideline range; district court reasonably weighed factors and exercised discretion	Affirmed — within‑Guidelines consecutive sentences are presumptively reasonable; no abuse of discretion shown

United States v. Haymond, 139 S. Ct. 2369 (addressing constitutionality of § 3583(k) and identifying three features that can implicate the jury-trial right)
Puckett v. United States, 556 U.S. 129 (explaining four-prong plain-error review)
United States v. Olano, 507 U.S. 725 (plain-error standard and discussion of prejudice and appellate correction)
Gall v. United States, 552 U.S. 38 (reasonableness review of sentencing decisions)
Marks v. United States, 430 U.S. 188 (framework for determining controlling opinion when Court is fragmented)
United States v. Lopez-Velasquez, 526 F.3d 804 (presumption of reasonableness for within-Guidelines revocation sentences)