United States v. KING, 2:00-cr-00313

David Worrells was convicted in 2001 for conspiracy to distribute over 50 grams of cocaine base and possession of a firearm by a felon, resulting in a lengthy prison sentence and a subsequent ten-year supervised release term.
His sentence was gradually reduced over the years due to appellate decisions, guideline amendments, and the First Step Act, with his release from prison in October 2021.
By March 2025, Worrells had served 41 months of supervised release with full compliance, stable employment, and a low/moderate risk classification.
Worrells sought early termination of supervised release after this period, mainly to travel outside the judicial district without restrictions.
The government opposed, citing the seriousness of the underlying offenses and no demonstrated undue harm from continued supervision.
The court evaluated the request under 18 U.S.C. § 3583(e)(1) and the factors set out in § 3553(a), ultimately denying the motion without prejudice.

Issue	Worrells' Argument	Government's Argument	Held
Early termination of supervised release	Has complied with all terms; wants freedom to travel; fully rehabilitated	Serious offenses; motion premature; no undue harm shown	Denied early termination without prejudice

United States v. Murray, 692 F.3d 273 (3d Cir. 2012) (need for sentence to reflect seriousness of offense is not relevant to early termination of supervised release)
United States v. Sheppard, 17 F.4th 449 (3d Cir. 2021) (purpose of supervised release is rehabilitation and integration, not punishment)
United States v. Johnson, 529 U.S. 53 (2000) (supervised release serves rehabilitative, not punitive, objectives)