United States v. Rockwell, 2:12-cr-00309

Defendant Marvin Rockwell pleaded guilty (Nov. 1, 2012) to possession of child pornography under 18 U.S.C. § 2252(a)(4)(B).
Sentenced March 15, 2013 to one day in custody (credit for time served) and a lifetime term of supervised release.
Defendant completed sexual deviancy evaluation and treatment, complied with supervision, and regularly met with his mental-health counselor.
Defendant suffers from advanced Parkinson’s disease limiting mobility, speech, and writing; submitted medical letter and video evidence of debility.
Previously moved for early termination (Dec. 2016); court denied that motion citing the offense and minimal intrusiveness of supervision.
Renewed motion (Dkt. #33) based on health and compliance; government opposed; Probation input considered. Court denied renewed motion on Oct. 19, 2017.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court should terminate supervised release under 18 U.S.C. § 3583(e)	The government opposed termination (public protection concern).	Rockwell: debilitating Parkinson’s and successful treatment make him harmless; termination warranted.	Denied — termination not warranted.
Whether defendant’s health sufficiently reduces risk of reoffense	Government: conviction itself evidences risk; offense requires little physical ability.	Rockwell: severe immobility and medical evidence show incapacity to reoffend.	Court: health limits defendant but not to degree that eliminates reoffense risk.
Whether changed circumstances since prior denial justify relief	Government: circumstances unchanged; public protection still weighs against termination.	Rockwell: submits additional medical documentation and video as new evidence.	Court: changes are not substantial enough to alter prior conclusion.
Proper scope of court’s discretion in § 3583(e) analysis	Government: discretionary factors under § 3553(a) counsel against termination.	Rockwell: asks court to exercise discretion based on conduct and justice.	Court: exercises discretion and declines to terminate after weighing § 3553(a) factors.

United States v. Emmett, 749 F.3d 817 (9th Cir. 2014) (district court has broad discretion to consider varied circumstances when deciding supervised-release termination)