United States v. Ray Daniels
689 F. App'x 194
| 4th Cir. | 2017Background
- Ray Shawn Daniels was sentenced to 21 months’ imprisonment after his third revocation of supervised release.
- Daniels had previously served 22 months on prior supervised-release revocations.
- The core statutory provision is 18 U.S.C. § 3583(e)(3), which caps imprisonment "on any such revocation" for class C or D felonies at 2 years.
- The PROTECT Act (2003) amended § 3583(e)(3) by adding the phrase "on any such revocation," prompting circuit courts to interpret whether the cap is per revocation or aggregate across revocations.
- Daniels argued the aggregate approach should apply to him because the PROTECT Act targeted child-exploitation offenses, not his property-related offense, and alternatively argued that the aggregate cap should equal the maximum supervised-release term under § 3583(b)(2).
- The district court imposed 21 months; the Fourth Circuit affirmed, holding the statutory language imposes a per-revocation cap.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prior time served on earlier supervised-release revocations counts toward the § 3583(e)(3) maximum | Daniels: PROTECT Act aimed at child-offenses; "on any such revocation" should not limit later revocations for non-child offenses | Government: The statute is unambiguous; the amendment imposes a per-revocation cap | Court: Rejects Daniels; § 3583(e)(3) is unambiguous and caps each revocation separately |
| Whether the aggregate imprisonment across revocations cannot exceed the maximum supervised-release term under § 3583(b)(2) | Daniels: Aggregate revocation sentences should be limited by the supervised-release statutory maximum (three years) | Government: No support; other circuits reject this aggregate-max argument | Court: Unpersuaded; rejects Daniels’ alternate aggregate-cap argument |
| Standard of review for statutory interpretation | N/A (issue raised on appeal) | N/A | Court: Reviews statutory interpretation de novo; arguments raised first on appeal reviewed for plain error |
| Whether remand or different remedy needed because Daniels previously served 22 months | Daniels: Prior service should reduce/limit current revocation | Government: Statutory cap per revocation allows full sentence | Court: Affirms 21-month sentence; prior time does not limit current revocation cap |
Key Cases Cited
- United States v. Webb, 738 F.3d 638 (4th Cir.) (explains standard of review for supervised-release revocation sentences)
- United States v. Under Seal, 709 F.3d 257 (4th Cir.) (statutory-interpretation review guidance)
- United States v. Hager, 288 F.3d 136 (4th Cir.) (discusses pre-PROTECT Act aggregate-time assumption)
- United States v. Perry, 743 F.3d 238 (7th Cir.) (holds prior revocation time does not limit later per-revocation maximum)
- United States v. Spencer, 720 F.3d 363 (D.C. Cir.) (concludes § 3583(e)(3) unambiguous as per-revocation cap)
- United States v. Hatcher, 560 F.3d 222 (4th Cir.) (explains when legislative history is unnecessary due to clear statutory text)
- United States v. Hunt, 673 F.3d 1289 (10th Cir.) (rejects limiting aggregate revocation time to supervised-release statutory maximum)