Cannot Challenge Original Sentence In Supervised Release Revocation Proceeding

US v. Sanchez: Way back when, Sanchez was convicted of being a felon in possession of a firearm and sentenced under ACCA. He was ultimately sentenced to 180 months in prison and a 5-year term of supervised release. Although Johnson came out while Sanchez was still in prison, he did not file a 2255 challenging his sentence. He was released and, ultimately, found himself facing revocation of his term of supervised release. At the revocation hearing, he argued that his ACCA sentence was improper under Johnson, but the district court refused to entertain the challenge, revoked Sanchez, and returned him to prison for 13 months (with more supervised release to follow).

On appeal, the Fourth Circuit affirmed. The court concluded that because Sanchez had not challenged his original sentence in either a direct appeal or 2255 proceeding the district court was correct to reject an attempt to challenge it at a revocation hearing. In doing so, the court reiterated that the place to challenge conditions of supervised release is on direct appeal from imposition of the original sentence, not in revocation proceedings that arise only from the alleged violation of the challenge conditions.