United States v. Johnny Brett Gregory, 20-13440

In 2006 Gregory pleaded guilty to possession with intent to distribute ≥50 g methamphetamine and to possessing a firearm in furtherance of a drug trafficking offense; he received 120 months + a consecutive 60 months, followed by five years of supervised release beginning July 19, 2019.
On July 24, 2020 Gregory moved pro se for early termination of supervised release after one year, citing compliance and “exemplary” post-conviction conduct.
The district court sua sponte denied the motion, stating only that it had “read and considered” Gregory’s motion and “reviewed information received from the Probation Office,” but gave no further explanation.
The government filed no response; a different judge had imposed the sentence 14 years earlier; the record contains no identified post-release Probation Office filing the district court relied on.
The Eleventh Circuit reviews denials of §3583(e)(1) motions for abuse of discretion but requires the district court to explain its decision sufficiently to allow meaningful appellate review under United States v. Johnson.
The Eleventh Circuit vacated the denial and remanded because the order and record lack enough information to permit meaningful appellate review of the §3553(a) factors’ application.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court adequately explained its denial of Gregory's motion for early termination of supervised release under 18 U.S.C. § 3583(e)(1)	Gregory argued the court denied relief without a reasoned basis and without showing consideration of the §3553(a) factors	District court asserted it had reviewed Gregory’s motion and Probation Office information (implying denial was warranted)	Vacated and remanded: the court’s terse statement and lack of identifiable record support prevent meaningful appellate review; more explanation is required (though explicit factor-by-factor recitation is not necessary)

United States v. Johnson, 877 F.3d 993 (11th Cir. 2017) (district courts must explain supervised-release termination denials adequately to allow meaningful appellate review)