United States v. LIPSCOMB, 1:10-cr-00221

Lorenzo Lipscomb pleaded guilty in 2011 to schemes producing false IRS refund claims (about $609,000 sought; approximately $95,036 paid) and to unemployment-benefit fraud (about $17,700 obtained). He also pleaded to related wire-fraud and aggravated identity-theft counts.
He was sentenced to concurrent terms with three years’ supervised release imposed for each scheme (36 months total supervised release), among other penalties.
After completing 28 of the 36 months of supervised release, Lipscomb filed a motion (July 29, 2019) seeking early termination, citing steady housing, full-time employment, and timely restitution payments.
The U.S. Probation Office raised no specific objection to termination but noted Lipscomb’s lengthy criminal history with multiple prior fraud convictions.
The Government opposed early termination, arguing mere compliance with supervision conditions is insufficient and Lipscomb had not shown new, unforeseen circumstances or exceptionally good behavior.
The Court considered 18 U.S.C. § 3583(e)(1) and the § 3553(a) factors and denied the motion, concluding compliance alone does not justify early termination and Lipscomb failed to demonstrate exceptional circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility under 18 U.S.C. § 3583(e)(1) for early termination	No dispute; defendant must have served >1 year to be eligible	Lipscomb is eligible because he served >1 year of supervised release	Eligible — Lipscomb met the statutory time requirement
Whether early termination is warranted by defendant's conduct and the interest of justice (considering 18 U.S.C. § 3553(a))	Opposes termination: mere compliance and steady employment do not constitute "exceptionally good" conduct or new/unforeseen circumstances	Requests termination based on stable housing, full-time employment, punctual restitution payments, and overall compliance	Denied: Court held compliance with supervision is baseline; no exceptional behavior or unforeseen circumstances shown; §3553(a) factors do not support early termination

U.S. v. Temple, 464 Fed. Appx. 541 (7th Cir. 2012) (recognizing district courts have broad discretion to consider early termination of supervised release while noting requirement to consider §3553(a) factors)