United States v. Todd Michael Jackson, 20-2495

Todd Jackson violated conditions of supervised release; the district court revoked release and imposed an 18‑month prison term followed by a new 24‑month term of supervised release.
The Sentencing Guidelines' advisory range for revocation was 3–9 months; the court imposed an above‑Guidelines 18‑month sentence.
The district court referenced public-protection/“incapacitation” and briefly mentioned retribution during sentencing.
The government did not request the additional supervised‑release term; the court imposed it anyway.
Jackson appealed both the prison term and the new supervised‑release term, arguing substantive unreasonableness and improper reliance on forbidden factors.
The Eighth Circuit affirmed, finding no abuse of discretion in either part of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 18‑month prison sentence (above 3–9 mo. advisory range) was substantively unreasonable	Jackson: sentence was excessive; shorter term would better serve rehabilitation	Government/District Court: sentence justified by repeated violations and need to protect public; court considered 18 U.S.C. § 3553 factors	Affirmed — no abuse of discretion; court reasonably weighed § 3553 factors and could impose an upward variance
Whether the district court abused its discretion by imposing a new 24‑month supervised‑release term when the government did not request it	Jackson: court should not have imposed a new term absent government request / relied on improper factors	Government/District Court: court may independently determine appropriate sentence regardless of parties’ recommendations; new term permitted under § 3583(e)(3)	Affirmed — court may impose a new supervised‑release term; it is the court’s responsibility to set sentence and did not err

United States v. Marrow Bone, 378 F.3d 806 (8th Cir. 2004) (review standard for above‑Guidelines revocation sentence)
United States v. Hall, 931 F.3d 694 (8th Cir. 2019) (repeated supervised‑release violations can justify upward variance; retribution is an excluded factor)
United States v. Larison, 432 F.3d 921 (8th Cir. 2006) (review for clear error in weighing § 3553 factors)
United States v. Carrillo, 982 F.3d 1134 (8th Cir. 2020) (disagreement with district court’s weighing of factors is not an abuse of discretion)
United States v. Boykin, 850 F.3d 985 (8th Cir. 2017) (significant weight to improper factors is reversible; mere mention is not)
United States v. Defoor, 535 F.3d 763 (8th Cir. 2008) (standard for imposing a new term of supervised release)
United States v. McKay, 775 F.3d 1016 (8th Cir. 2015) (district court’s responsibility to determine appropriate sentence independent of parties)
United States v. Lozoya, 623 F.3d 624 (8th Cir. 2010) (government’s recommendation does not bind the district court)