United States v. Michael Williams
691 F. App'x 758
| 4th Cir. | 2017Background
- Michael Crandale Williams completed a federal sentence, was transferred to Pennsylvania custody for an undischarged state term, and later returned to federal supervision.
- The district court revoked Williams’s supervised release for failing to follow probation officer instructions and imposed a four-month sentence.
- Williams claimed he never received a written statement of supervised-release conditions and was unaware federal supervision continued after his state sentence.
- He also argued the Eastern District of Pennsylvania (EDPA) probation office lacked jurisdiction to enforce his supervision.
- At the revocation hearing, an Eastern District of North Carolina (EDNC) probation officer testified he had informed Williams by phone on October 5, 2016, that Williams remained on supervised release and must comply with court orders.
- Williams did not raise the jurisdiction argument below; the Fourth Circuit reviewed it for plain error and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams was entitled to a written statement of conditions before revocation | Williams: Neither EDPA nor EDNC provided the required written statement, so revocation invalid | Government: Conditions were in original judgment and Williams had actual notice | Court: No merit — judgment and actual notice sufficed; revocation valid |
| Whether EDPA had authority to enforce supervision / jurisdiction issue | Williams: EDPA lacked jurisdiction to enforce, so revocation improper | Government: EDNC retained jurisdiction and sought revocation; EDPA did not enforce | Court: Reviewed for plain error; no plain error shown and EDNC enforced supervision |
| Whether the factual finding that Williams disobeyed probation officer was erroneous | Williams: Challenged the factual basis for revocation | Government: Probation officer testified to clear instruction and Williams’ noncompliance | Court: No clear error in finding violation; revocation upheld |
| Whether unpreserved jurisdictional claim warrants reversal under plain-error standard | Williams: Error affected substantial rights and fairness | Government: Error not shown; requirements for plain error unmet | Court: Plain-error standard not satisfied; no relief granted |
Key Cases Cited
- United States v. Padgett, 788 F.3d 370 (4th Cir. 2015) (review standard for supervised-release revocation)
- United States v. Arbizu, 431 F.3d 469 (5th Cir. 2005) (actual notice can cure failure to provide written conditions)
- United States v. Ramos-Santiago, 925 F.2d 15 (1st Cir. 1991) (criminal judgment can delineate supervised-release conditions)
- Henderson v. United States, 568 U.S. 266 (2013) (plain-error review for unpreserved claims)