United States v. Richard Rollins, 21-4009

Richard Colt Rollins appealed the district court’s revocation of his supervised release and a 24-month prison sentence.
A probation officer filed a revocation petition in 2008 alleging state-law criminal violations; Rollins did not enter federal custody on that petition until 2020 (12-year gap).
Rollins’ counsel filed an Anders brief asserting no meritorious issues but raising whether the 12-year delay prejudiced Rollins; the Government declined to file a brief and Rollins filed no pro se brief.
The district court revoked supervised release based on state-court jury convictions and imposed the 24-month revocation sentence.
The Fourth Circuit reviewed for abuse of discretion, found no unreasonable delay-related prejudice (noting Rollins remained in state custody and the jury verdicts provided a sufficient basis), and affirmed.
The court denied counsel’s withdrawal at this stage, instructed counsel to notify Rollins about the right to petition the Supreme Court, and set out procedures for a later motion to withdraw if appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a 12-year delay between filing the revocation petition and hearing violated rights	Rollins argued the delay was prejudicial and undermined his ability to contest violations	Government/district court relied on Rule 32.1 standards and lack of demonstrated prejudice	No unreasonable-prejudice shown; delay did not bar revocation
Whether jury convictions suffice to support revocation by preponderance	Rollins contested the underlying conduct	Court relied on jury verdicts as sufficient proof for revocation by a preponderance	Jury verdicts provided adequate basis to revoke supervised release

Anders v. California, 386 U.S. 738 (1967) (procedural standard for counsel to seek withdrawal when appeal appears frivolous)
Padgett v. United States, 788 F.3d 370 (4th Cir. 2015) (standard of review for revocation of supervised release)
Riley v. United States, 920 F.3d 200 (4th Cir. 2019) (revocation proceedings are not criminal proceedings and do not trigger full criminal rights)
Morrissey v. Brewer, 408 U.S. 471 (1972) (parole/revocation due process framework)
United States v. Ward, 770 F.3d 1090 (4th Cir. 2014) (speedy trial right does not apply to supervised-release revocation proceedings)
Moody v. Daggett, 429 U.S. 78 (1976) (no constitutional duty to provide adversary parole hearing before taking parolee into custody)
United States v. Santana, 526 F.3d 1257 (9th Cir. 2008) (delay relief requires both unreasonable delay and prejudice)
United States v. Tippens, 39 F.3d 88 (5th Cir. 1994) (delay may prejudice ability to contest violations or offer mitigation)
United States v. Goodon, 742 F.3d 373 (8th Cir. 2014) (state-court conviction/jury verdict can support federal supervised-release revocation)
United States v. Spraglin, 418 F.3d 479 (5th Cir. 2005) (same)
United States v. Huusko, 275 F.3d 600 (7th Cir. 2001) (same)