United States v. Preston Coleman, 709 F. App'x 802

Coleman, previously convicted under 18 U.S.C. § 922(g), was on supervised release after serving a term for being a felon in possession of a firearm.
He had prior violations: an earlier pretrial-release violation and a 2014 revocation for robbing a Dollar General (this appeal follows a second revocation).
In August 2015 an acquaintance, C.B., reported that Coleman raped her in her carport after driving her home from a club; police interviewed C.B. and arrested Coleman.
At the January 18, 2017 revocation hearing C.B. and two police officers testified; C.B.’s core testimony that Coleman forced intercourse was consistent across proceedings and corroborated by officers.
The district court found C.B. credible, determined by a preponderance of the evidence that Coleman committed rape (and that he failed to report the arrest within 72 hours), revoked supervised release, and ordered the remaining 24-month term of imprisonment.
Coleman appealed, arguing (1) the evidence was insufficient and the court should reweigh credibility, and (2) his sentence should be reduced for alleged assistance provided to the government.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to revoke supervised release for rape	Coleman: C.B.’s testimony was internally inconsistent and implausible; court should not credit it	Government/District Court: C.B.’s testimony consistently established nonconsensual intercourse and was corroborated by officers; credibility is for the factfinder	Court affirmed: district court did not clearly err; may rely on witness credibility and corroboration; not permitted to reweigh evidence
Whether sentence should be reduced for assistance provided to government	Coleman: he provided information to government meriting a sentence reduction	Government/District Court: no record evidence that Coleman’s information was helpful to merit a reduction	Court affirmed: Coleman failed to show assistance was helpful or that within-Guidelines sentence was unreasonable

Anderson v. City of Bessemer City, 470 U.S. 564 (explains deference to factfinder on credibility)
Darwich v. United States, 337 F.3d 645 (6th Cir. 2003) (appellate court will not reweigh evidence where two reasonable views exist)
Kontrol v. United States, 554 F.3d 1089 (6th Cir. 2009) (standards for revocation review)
Conatser v. United States, 514 F.3d 508 (6th Cir. 2008) (reasonableness standards for supervised-release revocation sentences)
Gall v. United States, 552 U.S. 38 (sets procedural reasonableness review principles for sentencing)
Lindo v. United States, 52 F.3d 106 (6th Cir. 1995) (revocation may be affirmed based on any single proven violation)
Carr v. United States, 421 F.3d 425 (6th Cir. 2005) (affirming revocation where parolee failed to notify officer of arrest)
Webster v. United States, [citation="426 F. App'x 406"] (6th Cir. 2011) (revocation-hearing standards)