US v. Melvin: Melvin was sentenced to life in prison, plus 300 months, plus five years of supervised release in 1998. In 2020, the district court reduced his sentence under the First Step Act to 306 months and he was released from prison the next year. Melvin had mental health issues that manifested in accusations of state criminal law violations that led to him being charged with violating conditions of his supervised release.
The parties agreed to a sentence of time served and no further term of supervised release. The district court said it agreed, but Melvin asked to address the court. He then proceeded to launch into what his own brief calls a “stream-of-conscious outburst” and what the district court called “one of the worst outbursts it had never seen in an open courtroom” (that said, what’s quoted in the opinion is pretty much just griping about probation officers). The district court it would “withdraw its previous rulings” because Melvin was “a danger to the law and to law enforcement and to the probation” officers. After a five-hour recess, the district court ordered that Melvin was to remain on supervised release, although it also ordered him committed to a mental hospital.
On appeal, the Fourth Circuit affirmed Melvin’s sentence. All agreed that once a sentence was imposed the district court could not simply change its mind and alter the sentence – the main issue was when a sentence was “imposed.” Following other circuits, the court rejected Melvin’s argument that the sentence was imposed once the district court agreed to the parties’ recommendation. Instead, a sentence is not imposed until both a sentence has been “unequivocally announced” and there has been a “formal break” in proceedings that shows sentencing has concluded.
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