United States v. Matta
777 F.3d 116
| 2d Cir. | 2015Background
- Matta pleaded guilty in 2007 to being a felon in possession of a firearm; released to supervised release in Aug. 2012 and subsequently incurred multiple supervised-release violation charges (assault/menacing, drug use, failure to comply with reentry and treatment programs, etc.).
- After plea dispositions in Oct. 2013 (some violations admitted; some state charges dismissed), the District Court revoked and resentenced Matta to 24 months imprisonment and 12 months supervised release (including 4 months in a residential reentry center).
- As a special condition of supervised release, the District Court required Matta to participate in a drug treatment or detoxification program but left to the Probation Department the discretion to select inpatient versus outpatient treatment.
- Matta did not object to that condition at sentencing and appealed after judgment, challenging (1) the delegation of the inpatient/outpatient decision to probation, (2) that the residential reentry term made the sentence exceed the statutory maximum, and (3) procedural and substantive reasonableness of the 24-month prison term.
- The Second Circuit vacated only the delegated-treatment special condition and remanded with instructions that the district court itself decide whether inpatient or outpatient treatment (if any) is appropriate; it affirmed the sentence in all other respects.
Issues
| Issue | Plaintiff's Argument (Matta) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether the district court may delegate to Probation the choice of inpatient vs outpatient drug treatment as a supervised-release condition | Delegation impermissibly cedes judicial sentencing power and affects significant liberty; court must impose such restrictive conditions itself | Matta failed to object at sentencing; review should be plain error and no clear precedent made the error plain | Delegation was impermissible; vacated that special condition and remanded for the district court to decide inpatient vs outpatient treatment |
| Whether the 4-month residential reentry condition made the sentence exceed the statutory maximum | Residential reentry is effectively imprisonment and thus makes total term exceed statutory maximum | Residential reentry is a community-confinement condition of supervised release authorized by statute and distinct from imprisonment | Reentry center term is a lawful supervised-release condition and does not exceed the statutory imprisonment maximum; claim rejected |
| Procedural reasonableness: whether court improperly considered conduct underlying dismissed state charges | Court improperly relied on conduct from dismissed charges to increase sentence | The reference was minimal; district court acknowledged charges were dismissed; defendant had opportunity to object | No plain error; procedural reasonableness upheld |
| Substantive reasonableness: whether 24-month prison term (above Guidelines 8–14 months) was unreasonable | Sentence is greater than necessary and exceeds Guidelines; thus substantively unreasonable | District Court adequately considered §3553(a) factors and acted within broad discretion to revoke and impose up to statutory maximum | Sentence was substantively reasonable and within the range of permissible decisions; affirmed |
Key Cases Cited
- United States v. Peterson, 248 F.3d 79 (2d Cir. 2001) (probation officer may decide minor supervision details but not conditions that effectively impose or increase punishment)
- United States v. Esparza, 552 F.3d 1088 (9th Cir. 2009) (vacating delegation that allowed probation officer to decide residential vs outpatient treatment because residential treatment implicates significant liberty interests)
- United States v. Mike, 632 F.3d 686 (10th Cir. 2011) (district court must impose restrictive conditions that affect significant liberty interests and support them with particularized findings)
- United States v. Reyes, 283 F.3d 446 (2d Cir. 2002) (describing the supervisory/executive role of probation officers in executing sentences rather than imposing them)
- United States v. Adler, 52 F.3d 20 (2d Cir. 1995) (distinguishing imprisonment from community confinement)
- Pepper v. United States, 562 U.S. 476 (2011) (explaining that supervised release follows imprisonment and serves a different purpose)