No Need to Specify Evidence Upon Which Supervised Release Revocation Is Based

US v. Patterson: Patterson was in a local jail while also serving a term of supervised release when his cellmate overdosed and was taken to the hospital. Patterson was eventually charged with violating his conditions of supervised release by possessing heroin and Xanax with intent to distribute as a result of that incident. He denied the charges and the district court held a contested revocation hearing in which it heard testimony from the cellmate (he got better) and others. The district court concluded that Patterson had provided the drugs the cellmate used to overdose, revoked his term of supervised release, and imposed a term of 39 months in prison.

On appeal, the Fourth Circuit affirmed Patterson’s revocation, but vacated his sentence. As to the revocation, the court rejected Patterson’s argument that the district court violated his due process rights by not specifying the particular evidence upon which it based its decision to revoke his term of supervised release. That was because “the record plainly shows the trial court’s rationale” in the way it “actively engaged with the witnesses and counsel.” The court also found the district court’s conclusion was not clearly erroneous. As to the sentence, however, the court agreed with Patterson that the district court did not provide a sufficient explanation for the sentence it imposed, because while it “gave a fulsome explanation” of the 3553(a) factors it “failed to not that it had considered Patterson’s mitigation points.”