United States v. TREUTELAAR, 2:20-cr-00235

Treutelaar was convicted in the Eastern District of Virginia of conspiracy to distribute crack cocaine and possessing a firearm in furtherance of a drug-trafficking offense; he was sentenced to 200 months imprisonment and concurrent 5-year terms of supervised release.
Sentence was amended under the First Step Act; supervised release began April 3, 2019, transferred to the W.D. Pa., and is scheduled to end April 2, 2024.
Defendant moved for early termination after roughly 2 years and 3 months of supervised release; Probation does not oppose and reports full compliance.
Treutelaar is employed as a tattoo artist, supports five children, seeks freedom to travel for work, and reports sobriety and community support.
The government opposed early termination, citing the seriousness of the offenses, Treutelaar’s criminal history, and congressional mandatory supervised-release terms.
The court considered the §3553(a) factors (nature of offense, deterrence, sentencing range, disparities, restitution) and concluded continued supervision is warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to terminate supervised release early under 18 U.S.C. §3583(e)	Treutelaar: eligible after >1 year; compliant, employed, family responsibilities, probation officer supports termination	Government: offense grave, career-offender history, statutory 5-year term and deterrence weigh against early release	Denied without prejudice; court considered §3553(a) factors and found termination not warranted or in the interest of justice
Whether Treutelaar’s conduct alone warrants termination	Compliance, rehabilitation, and employment show conduct warrants discharge	Compliance insufficient given severity and sentencing objectives	Court: compliance noted but not dispositive; supervision still serving deterrent/rehabilitative purposes
Whether §3553(a) factors (nature of offense, deterrence, sentencing range, disparities) favor termination	Guidelines range allows 3–5 years; served >1 year so eligible	Serious drug quantity, firearm use, need for deterrence, and to avoid disparities favor full term	Court: weighed factors and concluded five-year term remains appropriate

United States v. Davies, [citation="746 F. App'x 86"] (3d Cir. 2018) (discusses that early termination is generally proper only when new or unforeseen circumstances warrant it, but such circumstances are not strictly required)