991 F.3d 861
7th Cir.2021Background
- Stanford Wylie pleaded guilty to possession with intent to distribute >5 kg cocaine and qualified for the safety‑valve under 18 U.S.C. § 3553(f).
- PSR noted statutory penalties (prison 10 years–life; supervised release at least 5 years) but calculated the Guidelines supervised‑release range as 2–5 years and a prison Guideline range of 97–121 months.
- The government did not contest safety‑valve eligibility; the district court imposed 97 months’ imprisonment (the low end) but orally stated that the crime “requires” at least five years of supervised release and imposed a 5‑year term.
- Defense did not object when the court asked for legal objections to the proposed sentence.
- On appeal Wylie challenged only the length of supervised release, arguing the court erroneously believed it was bound by the statutory minimum despite safety‑valve relief.
- The Seventh Circuit vacated the supervised release term and remanded for reconsideration limited to the length of supervised release.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review / forfeiture | Wylie: de novo review for procedural error | Government: Wylie forfeited by failing to object; plain‑error review | Forfeited; reviewed for plain error under Olano (plain‑error framework applies) |
| Whether court erred by imposing 5 years supervised release | Wylie: court mistakenly thought statutory minimum (5 yrs) controlled despite safety‑valve and Guidelines 2–5 yrs | Government: court adopted PSR and statement of reasons showed 2–5 yrs, so no error or harmless | Court plainly erred in treating 5 years as required; vacated supervised‑release term and remanded for limited resentencing on length of supervision |
Key Cases Cited
- United States v. Olano, 507 U.S. 725 (plain‑error standard for unpreserved errors)
- Molina‑Martinez v. United States, 136 S. Ct. 1338 (presumption that Guidelines miscalculation affects substantial rights)
- Rosales‑Mireles v. United States, 138 S. Ct. 1897 (importance of correcting court‑made Guidelines errors to preserve legitimacy)
- United States v. Mobley, 833 F.3d 797 (sentencing is a package; supervised release part of sentence)
- United States v. Goodwin, 717 F.3d 511 (erroneous supervised‑release application can affect fairness and require remand)
- United States v. Lewis, 823 F.3d 1075 (analysis of remand for supervised‑release conditions and length)
- United States v. Gabriel, 831 F.3d 811 (no need to object after court definitively states intended course of action)