US v. Jameson: Steven Jamerson was on supervised release in 2023 when he was charged with violating several conditions. After his arrest, the court released Steven on bond, with his mother, Connie Jameson, as a third-party custodian. Connie was present at the bond hearing, agreed to be her son’s custodian, and that she “became responsible for his compliance with various conditions of release.” She also agreed that failure to do so could leave her “subject . . . to adverse consequences.”
Steven’s term of supervised release was revoked and he was sentenced to four months in prison, plus another eight months of supervised release. Rather than being immediately detained, Steven was ordered to self-surrender when instructed by the US Marshals Service. He was told at the revocation hearing that he was “released under the same terms of bond that you had when you came here to today.” Connie was in the courtroom for that hearing.
Steven and Connie were made aware of his report date, but Steven did not report as directed (he was arrested about a month later). Connie “did not take any action to ensure that the self-surrender occurred” and told investigators that “her son was a ‘grown person’ who was ‘old enough to be . . . responsible for himself.’” On the Government’s motion, Connie was held in criminal contempt and sentenced to three days in jail (stayed during the pendency of her appeal).
On appeal, the Fourth Circuit affirmed Connie’s contempt conviction. The court rejected her argument that, as of the revocation, there was no longer a “valid court order in pace” that required her to act as Steven’s custodian, holding that the Bail Reform Act allowed courts to extend bond to person following revocation and provide for self-surrender. The court also held that the bond order itself was clear enough to support a conviction for criminal contempt.
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