United States v. Muttaqin Abdullah
666 F. App'x 304
| 4th Cir. | 2016Background
- Muttaqin F. Abdullah was resentenced for being a felon in possession of a firearm; the district court imposed time served plus a three‑year term of supervised release.
- Abdullah had already served about 1 year and 4 months beyond the statutory maximum imprisonment before resentencing.
- Abdullah argued the district court lacked authority to impose supervised release because the total time (already served imprisonment plus supervised release if revoked) would exceed statutory maximums.
- The government relied on precedent treating imprisonment and supervised release as separate, successive sentences serving distinct purposes.
- The district court imposed supervised release in light of Abdullah’s threatening communication during initial sentencing and multiple in‑custody assaults and threats against correctional officers.
- The Fourth Circuit affirmed, holding supervised release was available and the three‑year term was not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument (Abdullah) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether the district court could impose supervised release after Abdullah had already overserved the statutory maximum imprisonment | Imposition of supervised release would push total exposure beyond statutory maximums and so was unauthorized | Supervised release is a separate, discretionary sentence distinct from imprisonment and may be imposed even if prior imprisonment exceeded statutory expectations | Court held supervised release was available; imprisonment and supervised release are separate and successive sentences |
| Whether the three‑year supervised release term was unreasonable | The three‑year term was excessive given the time Abdullah already served beyond the statutory maximum | The term was reasonable based on Abdullah’s threats and in‑custody violent conduct | Court found no abuse of discretion in imposing three years of supervised release |
Key Cases Cited
- United States v. Johnson, 529 U.S. 53 (2000) (supervised release is distinct from imprisonment and § 3624(e) does not reduce supervised release for excess time served)
- Gall v. United States, 552 U.S. 38 (2007) (sentencing review standard: abuse of discretion)
- United States v. Strieper, 666 F.3d 288 (4th Cir. 2012) (legal questions reviewed de novo)
- United States v. Buchanan, 638 F.3d 448 (4th Cir. 2011) (supervised release tolling and related principles)
- United States v. Neuhauser, 745 F.3d 125 (4th Cir. 2014) (supervised release has no function until confinement ends)