United States v. Saja Featherstone
703 F. App'x 300
| 5th Cir. | 2017Background
- Saja Featherstone was convicted in 2013 of conspiracy to possess with intent to distribute hydrocodone and received 13 months imprisonment plus three years supervised release.
- In 2016 the probation office alleged violations of her supervised release: leaving the judicial district without permission and associating with a known convicted felon, Amy Willard.
- At the revocation proceeding Featherstone initially admitted the violations but disputed whether she left voluntarily, claiming she was forced to go to Colorado; the district court asked follow-up questions and then construed her admission as withdrawn.
- After a five-day continued hearing, the district court found the violations proved and sentenced Featherstone to the statutory maximum two years imprisonment (plus 12 months supervised release).
- Featherstone appealed, arguing (1) the court erred by requiring additional evidence instead of allowing her to waive the guilt phase of the revocation hearing, and (2) the sentence was procedurally and substantively unreasonable.
- The Fifth Circuit affirmed, holding the waiver claim moot and finding no procedural or substantive error in the revocation sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court erred by refusing to accept plea/waiver of revocation hearing | Featherstone: she had right under Rule 32.1(b)(2) and Fifth Circuit precedent to waive the guilt phase and proceed to sentencing | Government: no concrete injury shown; court’s conduct does not present a live controversy | Moot; no live case or controversy so court will not issue advisory relief |
| Whether the district court relied on improper factors ("close and intimate" relationship) in sentencing | Featherstone: court improperly emphasized intimate association and failed to account for coercion by Willard | Government: reference to intimacy showed extent/duration of association and defendant’s awareness of Willard’s status | No procedural error; any such comment was not shown to be a dominant factor in the sentence |
| Whether the district court gave an adequate explanation for the sentence | Featherstone: explanation was inadequate | Government: court sufficiently considered §3553(a) factors and explained deterrence/public protection goals | No plain error; court implicitly and explicitly considered relevant factors and provided some explanation |
| Whether the sentence (statutory maximum) was substantively unreasonable | Featherstone: sentence failed to account for coercion and was excessive | Government: revocation sentences receive deferential review; district court may impose up to statutory maximum | Affirmed; sentence not plainly unreasonable and appellate court will not reweigh factor balancing |
Key Cases Cited
- Turner v. Rogers, 564 U.S. 431 (2011) (mootness / repetition exception discussed)
- Calderon v. Moore, 518 U.S. 149 (1996) (federal courts lack power to decide moot questions)
- C & H Nationwide, Inc. v. Norwest Bank Tex. NA, 208 F.3d 490 (5th Cir. 2000) (federal courts do not issue advisory opinions)
- Bd. of Sch. Comm’rs v. Jacobs, 420 U.S. 128 (1975) (case-or-controversy requirement)
- Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing substantive reasonableness of sentences)
- United States v. Warren, 720 F.3d 321 (5th Cir. 2013) (two-step plainly unreasonable review for supervised-release revocations)
- United States v. Miller, 634 F.3d 841 (5th Cir. 2011) (deferential review for revocation sentences)
- United States v. Receskey, 699 F.3d 807 (5th Cir. 2012) (§3583(e)(3) and consideration of §3553(a) factors on revocation)
- United States v. Rivera, 784 F.3d 1012 (5th Cir. 2015) (improper factor must be dominant to require reversal)
- United States v. Jones, 484 F.3d 783 (5th Cir. 2007) (upholding statutory-maximum revocation sentence)
- Rita v. United States, 551 U.S. 338 (2007) (need for district court to state reasons for sentence)
- United States v. Whitelaw, 580 F.3d 256 (5th Cir. 2009) (explanation standard in revocation cases)
- United States v. Teran, 98 F.3d 831 (5th Cir. 1996) (implicit consideration of §3553(a) factors can suffice)