United States v. Williams
2012 U.S. App. LEXIS 6620
| 3rd Cir. | 2012Background
- Williams pled guilty in 2004 to four counts of bank robbery and one count of conspiracy; sentenced to 48 months and three years of supervised release.
- She began supervised release on May 16, 2007, after completing the original sentence.
- Over the years she violated numerous supervised release conditions, including failing to report, positive drug tests, house arrest violations, and misrepresenting employment.
- The District Court repeatedly modified and revoked supervised release, imposing prison terms and additional supervised release, including a 19-month revocation sentence in 2009 with 12 months of supervision.
- In 2010 Williams argued the cumulative revocation imprisonment exceeded the statutory maximum; the District Court declined, and in 2011 revoked supervision and imposed a 24-month prison term with no supervision tail.
- Williams appeals, contending the 24-month sentence violates 18 U.S.C. § 3583(e)(3) and that the aggregate effects of prior revocations and § 3583(h) reduce the permissible post-revocation imprisonment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 3583(e)(3) cap post-revocation imprisonment at 2 years or 3 years? | Williams argues aggregate limits from § 3583(h) apply, reducing the cap. | The Government argues § 3583(e)(3) uses the offense’s statutorily authorized supervision term and sets a 2-year cap, independent of § 3583(h). | § 3583(e)(3) sets a 2-year cap; § 3583(h) does not aggregate-impose that cap on post-revocation imprisonment. |
| Does § 3583(h) impose an aggregate limit on revocation imprisonment? | Aggregate revocation imprisonment should reduce the permissible post-revocation term. | § 3583(h) caps the tail after imprisonment, not the per-revocation prison term. | § 3583(h) caps the tail of post-revocation supervision, not the per-revocation prison term under § 3583(e)(3). |
| Is Williams’ reading of the statute supported by the anti-superfluousness canon? | Canon requires reading statutes together to avoid surplus language. | Canon does not override the plain, independent meaning of § 3583(e)(3). | Canon does not require treating § 3583(e)(3) and § 3583(h) as an aggregate cap. |
| Is the rule of lenity applicable? | Ambiguity warrants lenity in interpreting § 3583(e)(3). | Statute is unambiguous; lenity does not apply. | Lenity does not apply; § 3583(e)(3) is unambiguous. |
Key Cases Cited
- United States v. Hampton, 633 F.3d 334 (5th Cir. 2011) (reading of § 3583(e)(3) harmonizes with § 3583(h))
- United States v. Jackson, 329 F.3d 406 (5th Cir. 2003) (per curiam on revocation imprisonment and tail limits)
- Johnson v. United States, 529 U.S. 694 (U.S. 2000) (legislative history informing 3583(e)(3) interpretation)
- Gregg v. United States, 226 F.3d 253 (3d Cir. 2000) (statutory interpretation and legislative history framework)
- Ron Pair Enters., Inc. v. United States, 489 U.S. 235 (U.S. 1989) (plain meaning and Chevron principles)
- Reno v. Koray, 515 U.S. 50 (U.S. 1995) (rule-of-lenity applicability conditions)
- United States v. Doe, 564 F.3d 305 (3d Cir. 2009) (plenary-review framework for statutory interpretation)