United States v. Travis Chalk
21-6693
| 4th Cir. | Sep 3, 2021Background
- Travis C. Chalk, pro se, moved under 18 U.S.C. § 3582(c)(1)(B) and § 404(b) of the First Step Act for a reduced sentence for a supervised-release revocation.
- The district court granted relief and reduced Chalk’s revocation sentence to the statutory maximum of 36 months’ imprisonment.
- Chalk appealed, arguing procedural errors and that he was entitled to a larger reduction.
- The Fourth Circuit held the district court decided Chalk’s motion without the benefit of United States v. Collington and identified two reversible errors: the court did not recalculate the Chapter 7 (policy statement) range and did not adequately explain imposing the 36‑month statutory maximum under § 3553(a).
- The probation officer’s First Step Act worksheet did not recalculate the policy statement range, the parties disputed the correct range, and the parties agreed the First Step Act lowered the range—making recalculation essential.
- The Fourth Circuit vacated the district court’s order and remanded for resentencing consistent with Collington.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court was required to recalculate the Chapter 7 policy‑statement range before resentencing under the First Step Act | Chalk: court must recalc and consider the new range | District court/Gov't: the reduction granted was acceptable without explicit recalculation | Court: must recalculate and consider the policy‑statement range; failure to do so was error |
| Whether the district court adequately explained imposing the 36‑month statutory maximum under § 3553(a) | Chalk: court failed to give individualized § 3553(a) reasoning and apply Collington | District court/Gov't: statutory max was appropriate as imposed | Court: explanation was inadequate; district court must apply § 3553(a) factors and explain decision |
| Whether Collington’s procedural requirements apply to First Step Act resentencings | Chalk: Collington controls and sets required steps | District court/Gov't: decision predated Collington, so court proceeded without its framework | Court: Collington applies; district courts must recalc Guidelines, correct Guideline errors/intervening law, and consider § 3553(a) factors |
| Remedy for the identified errors | Chalk: vacatur and remand for proper recalculation and explanation | District court/Gov't: no further relief needed | Court: vacated and remanded for resentencing under Collington |
Key Cases Cited
- United States v. Venable, 943 F.3d 187 (4th Cir. 2019) (discusses standards for supervised‑release revocation sentences)
- United States v. Collington, 995 F.3d 347 (4th Cir. 2021) (sets procedural requirements for First Step Act resentencings)
- United States v. Jackson, 952 F.3d 492 (4th Cir. 2020) (standard of review: abuse of discretion for First Step Act rulings)
- United States v. Slappy, 872 F.3d 202 (4th Cir. 2017) (district court must consider policy‑statement range for revocation sentences)
- United States v. Moulden, 478 F.3d 652 (4th Cir. 2007) (reaffirming requirement that district courts consider policy statements when imposing revocation sentences)