United States v. Lynch
1:16-cr-00018
E.D. Tex.Nov 9, 2017Background
- Defendant William Randy Lynch pleaded guilty in the Southern District of Texas to conspiracy to transport undocumented aliens (Class C felony) and was sentenced to 12 months’ imprisonment plus 2 years supervised release.
- He began supervised release on January 5, 2016; the case was transferred to the Eastern District of Texas in February 2016.
- A probation petition (filed Aug. 25, 2017) alleged three violations: committing another crime, illegal possession of a controlled substance, and leaving the judicial district without permission.
- At a Rule 32.1 hearing, Lynch admitted (pled “true”) that he left the Eastern District without probation officer permission. The parties agreed on a disposition.
- The magistrate judge found the admission established a Grade C violation (Criminal History I), and recommended revocation and a 3‑month prison term with no supervised release to follow.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lynch violated supervised release by leaving the district without permission | Probation/Government: Lynch left the Eastern District without permission, violating the condition prohibiting leaving the district | Lynch: admitted the allegation (pled true); agreed to proposed disposition | Court: Found violation proved by a preponderance of the evidence (pled true) and classified it as a Grade C violation |
| Appropriate disposition for Grade C violation | Government: revoke supervised release and impose a custodial sanction consistent with guidelines (3–9 months) | Lynch: agreed to 3 months’ imprisonment and no further supervised release | Court: Adopted parties’ agreement; recommended 3 months’ imprisonment, no supervised release to follow |
| Application of U.S.S.G. policy on revocation | Government: guidelines provide advisory 3–9 month range for Grade C, CH I | Lynch: agreed sentencing within guideline range (3 months) | Court: Considered guidelines as advisory and followed them in recommending the 3‑month term |
| Procedural rights following the magistrate judge’s report | Government: standard rule that parties may object to magistrate recommendations | Lynch: not contesting at the hearing; retains right to object within 14 days | Court: Informed parties of 14‑day objection period and consequences of failing to object |
Key Cases Cited
- United States v. Rodriguez, 23 F.3d 919 (5th Cir. 1994) (procedural reference for magistrate judge handling of supervised‑release revocation matters)
- United States v. Price, [citation="519 F. App'x 560"] (11th Cir. 2013) (Chapter 7 policy statements governing revocation are non‑binding)
- Rodriguez v. Bowen, 857 F.2d 275 (5th Cir. 1988) (failure to timely object to magistrate report waives de novo review)
- Douglass v. United Servs. Auto. Ass'n, 79 F.3d 1415 (5th Cir. 1996) (timely objections to magistrate reports required to preserve appellate review)