United States v. Ray L. Alexander, 21-2456

Alexander pleaded guilty in Puerto Rico to making a false statement to a federal agency (18 U.S.C. § 1001) and was sentenced to three months’ imprisonment and three years’ supervised release.
The sentencing court transferred supervision to the Southern District of Illinois under 18 U.S.C. § 3605.
While on supervision in Illinois, Alexander was accused of possessing firearms/ammunition and a bulletproof vest, failing to notify probation of a police contact, and failing to file monthly reports.
At the revocation hearing Alexander represented himself, admitted failing to report the first stop and monthly reports, denied owning the weapons but conceded the car with the guns was “essentially” his; police testified they observed a gun in plain view and recovered a rifle, ~50 rounds, magazines, and a vest.
The district judge credited the government’s witnesses, found the violations proved by a preponderance, revoked supervision, and sentenced Alexander to 10.5 months’ incarceration plus one year of supervised release (the parties jointly recommended 10.5 months).
On appeal Alexander raised jurisdictional challenges, disputed the sufficiency of the evidence, attacked the sentence, and attempted to collaterally attack his underlying Puerto Rico conviction; the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to revoke after transfer	Transfer statute permits receiving district to revoke supervision	Only Puerto Rico court (where plea was made) could revoke	Transfer under §3605 valid; Southern District had authority to revoke
Sufficiency of evidence for violations (guns, reporting)	Testimony and physical recovery from car where Alexander was sole occupant supported possession and reporting failures	Guns belonged to business/others; only government witnesses supported possession	No clear error: judge reasonably credited government; possession and reporting violations proved
Sentencing / waiver	Joint recommendation of 10.5 months waived challenge to term; additional supervision and total sentence within statutory limits and reasonable	Disputes characterization of criminal history; claims judge exceeded authority, sentence substantively unreasonable, and prosecutor’s PR promise barred further recommendations	Challenge to incarceration waived; sentence below statutory maximum and not plainly unreasonable; prosecutor’s PR promise did not bar revocation recommendations
Collateral attack on underlying conviction	Underlying Puerto Rico conviction and sentencing valid; revocation proceeding not vehicle to relitigate	Argues Puerto Rico court lacked subject-matter or personal jurisdiction over his underlying case	Collateral attack barred; PR court had subject-matter and personal jurisdiction; jurisdictional arguments meritless

United States v. Falls, 960 F.3d 442 (7th Cir. 2020) (standard of review for revocation findings)
United States v. Lockwood, 840 F.3d 896 (7th Cir. 2016) (credibility determinations can support revocation findings)
United States v. Ford, 22 F.4th 687 (7th Cir. 2022) (occupying a vehicle where guns are found can support possession finding)
United States v. Parra, 402 F.3d 752 (7th Cir. 2005) (possession can be inferred from control of vehicle containing firearms)
United States v. Nichols, 789 F.3d 795 (7th Cir. 2015) (joint sentencing recommendation waives challenge to term)
United States v. Propst, 959 F.3d 298 (7th Cir. 2020) (right to be sentenced on accurate information)
United States v. Dawson, 980 F.3d 1156 (7th Cir. 2020) (plainly unreasonable standard for revocation sentences)
United States v. St. Clair, 926 F.3d 386 (7th Cir. 2019) (may not collaterally attack underlying conviction in revocation proceedings)
United States v. Alvarez-Machain, 504 U.S. 655 (1992) (discussion of personal jurisdiction principles)