United States v. Robert Padgett, 788 F.3d 370

Robert L. Padgett had two consolidated federal convictions (1998 conspiracy to distribute cocaine base; 2009 attempted escape), each with terms of supervised release.
In 2013 the district court revoked his supervised release and imposed short prison time followed by concurrent supervised release; in 2014 the Government alleged new violations and sought a second revocation.
Alleged 2014 violations: possession of a firearm, two counts of battery, and possession of a switchblade; after an evidentiary hearing the court found by a preponderance that Padgett possessed a firearm, committed one battery, and possessed a switchblade.
Evidence supporting the firearm finding: (1) officer heard five shots and found shell casings; (2) eyewitness Melanie Curnutte identified Padgett firing five shots; (3) gunshot residue found on Padgett consistent with discharge or exposure.
Padgett offered alibi testimony from his girlfriend asserting he was inside her home when shots occurred and cross-examined the Government’s witnesses to show alternative explanations for residue transfer.
The district court revoked supervised release and sentenced Padgett to consecutive 10- and 14-month prison terms (24 months total), followed by new concurrent supervised-release terms; Padgett appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court clearly erred in finding Padgett possessed a firearm	Padgett argued the evidence was insufficient; alibi and alternative residue transfer undermined the finding	Government contended eyewitnesses, shell casings, and gunshot-residue evidence made possession more likely than not	Court held the possession finding was not clearly erroneous (preponderance standard met)
Whether the revocation sentence was plainly unreasonable	Padgett argued the 24-month combined prison term was excessive given circumstances	Government argued the sentence fell within the Guidelines range and was justified by repeated and serious violations	Court held the sentence reasonable: within policy range, adequately explained, and not an abuse of discretion

United States v. Copley, 978 F.2d 829 (4th Cir. 1992) (revocation reviewed for abuse of discretion)
United States v. Preacely, 702 F.3d 373 (7th Cir. 2012) (factual findings on revocation reviewed for clear error)
United States v. Oquendo-Rivera, 586 F.3d 63 (1st Cir. 2009) (same)
United States v. Manigan, 592 F.3d 621 (4th Cir. 2010) (preponderance standard for supervised-release revocation findings)
United States v. Zayyad, 741 F.3d 452 (4th Cir. 2014) (reliance on a clearly erroneous fact is an abuse of discretion)
United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (revocation sentence review: plain unreasonableness standard)
United States v. Moulden, 478 F.3d 652 (4th Cir. 2007) (sentencing court must consider Chapter 7 Guidelines and § 3553(a) factors)
United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (in-range revocation sentences presumed reasonable)