United States v. Winfield
2012 U.S. App. LEXIS 922
| 4th Cir. | 2012Background
- Winfield pled guilty to distribution crack cocaine; sentenced to 51 months and 3 years' supervised release starting Aug 31, 2007.
- Probation officer filed violations Oct 2, 2009, later amended to include state charges and notification issues.
- May 18, 2010 hearing found technical violations; 12-month imprisonment imposed; order did not explicitly revoke supervised release.
- September 17, 2010 hearing addressed state-conviction violations; court found violations and imposed an additional 12-month sentence and explicitly revoked supervised release without a new term of supervised release.
- Winfield appeals, arguing lack of jurisdiction under 18 U.S.C. § 3583(e)(3) after alleged revocation; government argues revocation does not terminate jurisdiction and second hearing is permissible.
- Court discusses Johnson v. United States to interpret revocation, recall, and continued jurisdiction after re-incarceration for violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 3583(e)(3) terminate jurisdiction after revocation? | Winfield argues revocation ends court's authority. | Government contends revocation does not terminate the release; recall remains. | Revocation does not terminate jurisdiction. |
| May court hold a second violation hearing and impose more prison time after revocation? | Winfield asserts no authority to adjudicate further violations post-revocation. | Government maintains jurisdiction to hold second hearing and impose sentences. | Court had jurisdiction to hold second hearing and impose sentence. |
| Is Rule 35(a) or § 3583(e) governing for corrections/second sentences in this context? | Winfield contends Rule 35(a) limits corrections; could not justify later sentence. | Government argues § 3583(e) governs corrections; Rule 35(a) not controlling here. | § 3583(e) governs; Rule 35(a) does not limit this context. |
Key Cases Cited
- United States v. Johnson, 529 U.S. 694 (2000) (revocation does not terminate; recall continues during re-incarceration)
- United States v. Ide, 624 F.3d 666 (4th Cir. 2010) (plain meaning of § 3583(e)(3))
- United States v. Barton, 26 F.3d 490 (4th Cir. 1994) (jurisdiction to hold hearings related to revocation after period expires)
- United States v. Vargas, 564 F.3d 618 (2d Cir. 2009) (post-revocation authority to correct omissions; term continues to have effect)
- United States v. Johnson, 243 F. App'x 666 (3d Cir. 2007) (unpublished; district court authority to hold bifurcated hearings)