United States v. Troy Slay
681 F. App'x 804
| 11th Cir. | 2017Background
- Defendant Troy Slay pleaded guilty to possession with intent to distribute 500g of cocaine and was sentenced with a special supervised-release condition prohibiting new credit charges, new lines of credit, or major purchases without probation officer approval.
- Slay filed an unopposed motion under 18 U.S.C. § 3583(e)(2) asking the district court to remove that special condition, explaining it hindered his employment as a sales representative where he must often front client-event expenses reimbursed weeks later.
- The government and probation office did not oppose the motion and Slay submitted an employer email confirming typical out-of-pocket expenses of $50–$500 per day and delayed reimbursement.
- The district court summarily denied the motion, stating the condition only required prior approval and did not forbid use of credit; it gave no analysis under § 3553(a) or responsive findings addressing Slay’s job-related burdens.
- The Eleventh Circuit reviewed for abuse of discretion and found the district court’s limited explanation insufficient, vacating and remanding for the court to consider the § 3553(a) factors and address the points raised by Slay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying a § 3583(e)(2) motion to modify supervised-release conditions | Slay: condition unduly burdens job performance; government didn’t oppose; probation can still monitor finances via financial-disclosure condition | District court: condition does not prohibit credit use, only requires prior approval | Court: Abuse of discretion—district court failed to show it considered § 3553(a) factors or respond to Slay’s evidentiary points; vacated and remanded |
| Whether the district court needed to articulate § 3553(a) factors in denying the motion | Slay: district court must permit review by showing it considered § 3553(a) factors | Implicit district-court position: brief statement sufficient because condition allows monitoring | Court: If record doesn’t show consideration of § 3553(a), remand is required |
| Whether special condition was reasonably related to rehabilitative goals of supervised release | Slay: condition undermines rehabilitation by impeding employment; other conditions suffice to monitor finances | District court: prior-approval requirement reasonably limits financial risk | Court: District court did not explain how condition served rehabilitative ends; explanation required on remand |
| Whether unopposed status of motion affects analysis | Slay: lack of opposition supports modification | Government: (no opposition presented) | Court: Unopposed motion and record facts weigh in favor of requiring a reasoned explanation; still need § 3553(a) analysis |
Key Cases Cited
- United States v. Serrapio, 754 F.3d 1312 (11th Cir. 2014) (standard: review modification of supervised-release/probation conditions for abuse of discretion)
- United States v. McClamma, 613 F. App’x 846 (11th Cir. 2015) (per curiam) (appellate review of supervised-release modifications for abuse of discretion)
- United States v. Frazier, 387 F.3d 1244 (11th Cir. 2004) (en banc) (abuse-of-discretion standard and requirement to affirm absent clear error of judgment or wrong legal standard)
- United States v. Douglas, 576 F.3d 1216 (11th Cir. 2009) (per curiam) (remand required when record does not show district court considered § 3553(a) factors)
- Johnson v. United States, 529 U.S. 53 (2000) (describing supervised release’s rehabilitative aims and transition to community life)