United States v. Randy Campos, 922 F.3d 686

Campos pleaded guilty to conspiracy to distribute heroin within 1,000 feet of a vocational school/college in violation of federal drug statutes and was originally sentenced in July 2014 to 60 months imprisonment and an 8‑year term of supervised release.
Supervision began January 29, 2016; Campos soon violated supervised‑release conditions by failing to report and by not following probation instructions.
At revocation, the probation officer’s worksheet and the district court treated an 8‑year term as a mandatory minimum for supervised release following revocation.
The district court revoked release, sentenced Campos to 9 months imprisonment, and again imposed an 8‑year term of supervised release without explanation and without crediting time already served.
The court of appeals concluded the district court erred: no statutory mandatory minimum applies to supervised‑release terms after revocation (18 U.S.C. § 3583(h)); only a maximum (the original statutory maximum minus the reimposed imprisonment) applies.
Because Campos did not object below, the Fifth Circuit reviewed for plain error, found the error was clear and affected substantial rights, and vacated the 8‑year supervised‑release term, remanding for resentencing free of the non‑existent mandatory minimum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court plainly erred by treating an 8‑year supervised‑release term as a mandatory minimum on revocation	Campos: No mandatory minimum applies after revocation; the court therefore erred and had discretion to impose a different term	Government: The error was clear but did not affect substantial rights; alternatively, the 8‑year term is justifiable on the record (Campo’s absconding)	Court: Clear error; affected substantial rights because the court believed it lacked discretion; vacated the 8‑year term and remanded for resentencing

United States v. Putnam, 806 F.3d 853 (5th Cir. 2015) (plain‑error review of supervised‑release sentencing)
Molina‑Martinez v. United States, 136 S. Ct. 1338 (2016) (an incorrect Guidelines range can establish harm for plain‑error review)
United States v. Dominguez Benitez, 542 U.S. 74 (2004) (standard on reasonable probability affecting outcome)
United States v. Huor, 852 F.3d 392 (5th Cir. 2017) (defendant bears burden to show plain error)
United States v. Sanchez‑Arvizu, 893 F.3d 312 (5th Cir. 2018) (reliance on incorrect Guidelines range often satisfies substantial‑rights prong when record is silent)
United States v. Olano, 507 U.S. 725 (1993) (framework for correcting forfeited error)
Rosales‑Mireles v. United States, 138 S. Ct. 1897 (2018) (failure to correct plain Guidelines error undermines fairness; risk of unnecessary deprivation of liberty)
Glover v. United States, 531 U.S. 198 (2001) (sentence‑calculation errors can result from judicial or presentence‑report mistakes)