199 F. Supp. 3d 1
D.D.C.2016Background
- Defendant Kenneth Longerbeam pled guilty (Feb 20, 2008) to one count of interstate travel to engage in prohibited sexual conduct and was sentenced May 22, 2008 to 36 months imprisonment and 10 years supervised release with sex-offender treatment and registration conditions.
- The Court previously denied an earlier motion to terminate supervised release on Aug 4, 2015 and permitted re-filing within one year.
- Longerbeam filed a renewed motion seeking early termination after nearly six years on supervised release, citing full compliance: completion of sex-offender therapy, registration in Maryland, steady employment, AA/NA participation, and stable personal relationships.
- The Government opposed the motion; the U.S. Probation Office recommended denial.
- The Court considered the statutory framework (18 U.S.C. § 3583(e)(1) and § 3553(a)) and applicable precedents regarding when changed circumstances or exceptionally good behavior justify early termination.
- The Court denied the renewed motion, concluding that defendant’s compliant conduct—while commendable—did not amount to the unusual or extraordinary circumstances required to terminate supervised release early.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should terminate supervised release early under 18 U.S.C. § 3583(e)(1) after ~6 years of compliant supervision | The Government argued termination is unwarranted given the nature of the offense and sentencing considerations; opposed early termination | Longerbeam argued that sustained compliance, completion of treatment and registration, stable employment and personal life warrant termination | Denied: compliance alone is insufficient; no unusual or extraordinary circumstances shown to justify early termination under § 3583(e)(1) |
Key Cases Cited
- United States v. Mathis-Gardner, 783 F.3d 1286 (D.C. Cir. 2015) (district courts must consider specified § 3553(a) factors before denying early termination)
- United States v. Lussier, 104 F.3d 32 (2d Cir. 1996) (changed circumstances like exceptionally good behavior may justify modification/termination)
- Gall v. United States, 552 U.S. 38 (2007) (district courts should consider all § 3553(a) factors at sentencing)
- United States v. Etheridge, 999 F. Supp. 2d 192 (D.D.C. 2013) (full compliance ordinarily does not constitute exceptional behavior warranting early termination)
- United States v. McKay, 352 F. Supp. 2d 359 (E.D.N.Y. 2005) (model conduct under supervision is expected and not a basis for early termination)
- United States v. Medina, 17 F. Supp. 2d 245 (S.D.N.Y. 1998) (unblemished postincarceration conduct alone insufficient; exception would swallow the rule)
- United States v. Caruso, 241 F. Supp. 2d 466 (D.N.J. 2003) (defendant must show something unusual or extraordinary beyond full compliance)