US v. Watson: Watson was sentenced in 2018 to a term of imprisonment and supervised release. If he violated his conditions of supervised release, he faced a statutory maximum term of imprisonment of 48 months. He did violate, “almost immediately upon leaving prison,” leading to the revocation of his term of supervised release. The district court imposed a sentence of 41 months in prison, followed by a lifetime of supervised release, to include as a condition that he serve home detention of approximately 21 months.
On appeal, the Fourth Circuit vacated Watson’s sentence. It agreed with Watson that the combined terms of imprisonment and home detention imposed by the district court exceeded the 48-month statutory maximum. They must be considered separate, as home detention is considered an “alternative” to incarceration. The court also rejected the Government’s argument that even if that was the case that home detention time didn’t not count as 1-to-1 equivalent to incarceration.
Congrats to the Defender office in South Carolina on the win!
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