United States v. Ulyessie Huggins
660 F. App'x 174
| 3rd Cir. | 2016Background
- Huggins pleaded guilty to possession with intent to distribute cocaine/crack, was sentenced to 60 months and six years supervised release.
- About six weeks after release, he was arrested in state court for selling heroin and later convicted of possession-related offenses that occurred during supervised release.
- The Government obtained a warrant alleging violation of the supervised-release condition forbidding commission of a state crime; Huggins appeared, admitted the violation, and waived a revocation hearing.
- The District Court revoked supervised release and imposed a 20-month prison sentence (within the 18–24 month advisory Guidelines range for a Grade A violation).
- Huggins filed a pro se notice of appeal; appointed counsel filed an Anders brief and moved to withdraw, concluding no non-frivolous issues existed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to revoke supervised release | N/A — court had jurisdiction | N/A | District Court had jurisdiction under 18 U.S.C. §§ 3231, 3583(e)(3) (no dispute) |
| Voluntariness of admission / waiver of hearing | Huggins implies admission/waiver may have been involuntary | Admission and waiver were knowing, counseled, and voluntary after colloquy and counsel’s assurances | Admission and waiver were voluntary; no nonfrivolous challenge |
| Procedural reasonableness of revocation sentence | Sentence was procedurally improper or insufficiently explained (argued hypothetically) | Court followed Gunter’s three-step procedure, calculated Guidelines, denied departure, considered §3553(a) factors | Procedurally reasonable; District Court adequately considered factors |
| Substantive reasonableness of revocation sentence | Sentence was substantively unreasonable (argued hypothetically) | Given mandatory revocation for controlled-substance violation, recidivism, timing, 20 months was within reasonable range | Substantively reasonable; no basis for reversal |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (procedures for appointed counsel seeking to withdraw on appeal)
- Broce v. United States, 488 U.S. 563 (1989) (review of convictions based on guilty pleas limited to voluntariness and counsel)
- Gall v. United States, 552 U.S. 38 (2007) (procedural and substantive reasonableness framework for sentencing)
- Tomko v. United States, 562 F.3d 558 (3d Cir. 2009) (sentencing review standards in Third Circuit)
- Gunter v. United States, 462 F.3d 237 (3d Cir. 2006) (three-step procedure for revocation sentencing)
- Bungar v. United States, 478 F.3d 540 (3d Cir. 2007) (mandatory revocation for possession of controlled substance under §3583(g))
- Youla v. United States, 241 F.3d 296 (3d Cir. 2001) (Anders guidance under Third Circuit local rule)