United States v. Steve Washington, 673 F. App'x 341

Appellant Steve Dantay Washington had supervised release revoked after repeated violations involving being expelled from a halfway house for rule breaches.
Washington previously committed supervised-release violations that led to modifications and a prior revocation, showing a pattern of noncompliance.
After the first halfway-house ejection the district court allowed Washington to return as a second chance; he was later ejected again.
The district court revoked supervised release and imposed a 12-month prison term within the advisory Policy Statement range.
Washington appealed, arguing the sentence was plainly unreasonable and unduly punitive given his employment and rehabilitative progress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 12-month revocation sentence was unreasonable	Washington: sentence is unduly punitive, undermines reentry and overstates severity of violations	Govt: district court acted within broad discretion for revocation sentencing given repeated violations	Affirmed — sentence was not plainly unreasonable and fell within permissible range
Whether district court considered applicable factors	Washington: court failed to adequately weigh rehabilitation and employment	Govt: court considered Policy Statement and §3553(a) factors and defendant's breach pattern	Affirmed — court considered advisory range and relevant factors

United States v. Padgett, 788 F.3d 370 (4th Cir. 2015) (appellate review of revocation sentences is deferential; vacatur only if sentence outside statutory maximum or plainly unreasonable)
United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (revocation sentence substantively reasonable if court states proper basis; pattern of violations supports harsher term)
United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (district court should primarily sanction breach of trust, with lesser weight to underlying offense seriousness)