United States v. Todd Jones, 2014 U.S. App. LEXIS 23923

Jones pleaded guilty to a conspiracy to distribute crack cocaine; other charges were dismissed; he received a reduced sentence and five years supervised release.
While on supervised release he repeatedly failed to comply with conditions: missed monthly reports, missed probation appointments, tested positive for marijuana, and had multiple run-ins with police/state charges (some unprosecuted).
Probation filed a revocation petition; Jones admitted possession of marijuana and two failures to report; other allegations were withdrawn.
The probation officer’s guidelines calculation classified Jones’s violations as Grade B, Criminal History Category I, yielding a 4–10 month Guidelines range; statutory maximum on revocation was three years.
The district court sentenced Jones to four months imprisonment (the bottom of the Guidelines range) followed by 36 months supervised release. Jones appealed as plainly unreasonable and raised due-process and § 3553 argument failures.

Issue	Plaintiff's Argument (Jones)	Defendant's Argument (Government/District Court)	Held
Whether revocation sentence was plainly unreasonable	Sentence (4 months + 36 months supervision) is excessive given minor violations and his post-release accomplishments	Sentence is within Guidelines range and appropriately justified by repeated noncompliance	Affirmed — not plainly unreasonable
Whether court violated due process by not considering alternatives to incarceration	Court failed to consider non-incarceration alternatives before revocation	No due-process rule requires explicit consideration of alternatives; Jones received required process	Affirmed — no due-process violation (Black v. Romano controls)
Whether § 3553(a) and Chapter 7 policy statements were ignored	Court did not properly weigh § 3553 factors and Chapter 7 guidance	Court considered Chapter 7 (7B1.4), reviewed report and explained reasons; § 3553 factors need not be recited checklist-style	Affirmed — court adequately considered applicable factors
Whether revocation was mandatory such that discretion was limited	(Implicit) Court should have more discretion despite marijuana possession	18 U.S.C. § 3583(g) mandates revocation upon possession of a controlled substance; revocation was proper	Affirmed — revocation required by statute (possession mandates revocation)

Black v. Romano, 471 U.S. 606 (U.S. 1985) (Due process does not require courts to consider alternatives to incarceration before revoking probation)
Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (Due process protections in parole revocation proceedings)
Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (Right to counsel in probation revocation under certain circumstances)
U.S. v. Kizeart, 505 F.3d 672 (7th Cir. 2007) (Appellate standard: review for plain unreasonableness on revocation sentencing)
U.S. v. Hondras, 296 F.3d 601 (7th Cir. 2002) (Possession of a controlled substance requires revocation under § 3583(g))
Gall v. U.S., 552 U.S. 38 (U.S. 2007) (Sentence within Guidelines is presumptively reasonable; scope of appellate review)
U.S. v. Pollock, 757 F.3d 582 (7th Cir. 2014) (District court must give an adequate, reviewable statement of reasons consistent with § 3553(a))
U.S. v. Conaway, 713 F.3d 897 (7th Cir. 2013) (Explanation requirement for revocation sentences sufficient to permit appellate review)