United States v. William Elijah Trailer
827 F.3d 933
| 11th Cir. | 2016Background
- In 2011 William Trailer pleaded guilty to failing to register as a sex offender (18 U.S.C. § 2250) and was sentenced to 37 months’ imprisonment and a life term of supervised release; a special condition prohibited contact with minors under 18.
- Supervised release began August 2014; in February 2015 the probation officer petitioned to revoke based on Trailer living with his wife’s four minor children, ignoring instructions to avoid contact, violating Alabama’s Community Notification Act, and lying to his probation officer.
- At the revocation hearing Trailer admitted the violations. The district court revoked supervised release, calculated an advisory imprisonment range of 18–24 months (Class B violation, Crim. Hist. V), and imposed 18 months’ imprisonment.
- The district court also continued a life term of supervised release with conditions similar to the original sentence; Trailer objected that the life term was excessive.
- Trailer argued the life term was greater than necessary given his post‑offense conduct, the previous lifetime sex‑offender registration, and research on recidivism; the district court relied on the nature of the original offense, Trailer’s willful violations and lies, and deterrence/public‑protection considerations.
- The Eleventh Circuit affirmed, holding the life term was within the statutory range and reasonable under 18 U.S.C. § 3553(a); the Court noted Trailer may seek modification or early termination under 18 U.S.C. § 3583(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether imposing a life term of supervised release upon revocation is substantively unreasonable | Government: life term is authorized and appropriate given Trailer’s original offense and his willful supervised‑release violations | Trailer: life term is greater than necessary given his post‑conviction behavior, lifetime registration, and research on sex‑offender recidivism | Affirmed: life term is within statutory authorization and not substantively unreasonable given § 3553(a) factors |
Key Cases Cited
- United States v. Cubero, 754 F.3d 888 (11th Cir. 2014) (abuse‑of‑discretion reasonableness review framework)
- United States v. Sweeting, 437 F.3d 1105 (11th Cir. 2006) (review of sentences imposed upon supervised‑release revocation)
- United States v. Pugh, 515 F.3d 1179 (11th Cir. 2008) (burden on appellant to show sentence unreasonable)
- United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (standard for vacating a sentence as substantively unreasonable)
- United States v. Mathis‑Gardner, 783 F.3d 1286 (D.C. Cir. 2015) (appealability of district court denial of motion to shorten supervised release)
- United States v. Gammarano, 321 F.3d 311 (2d Cir. 2003) (same)
- United States v. Pregent, 190 F.3d 279 (4th Cir. 1999) (same)