United States v. Melvin, No. 20-1158 (3d Cir. 2020)
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Melvin pleaded guilty to possession and transfer of a machine gun, being a felon in possession of a firearm, engaging in an illegal firearms business, and conspiracy. Melvin began his three-year term of supervised release in 2017. With 15 months of supervised release yet to be completed, Melvin sought early termination under 18 U.S.C. 3583(e), arguing “his post-offense conduct and successful completion of well over one year of supervised release” rendered any additional period of supervised release “superfluous to afford adequate deterrence … or to serve the public good.” He “has worked steadily, continued and strengthened his relationships with his children and new wife, and impressed his Probation Officer.”
The Third Circuit vacated the denial of the motion; the district court abused its discretion in requiring Melvin to show that changed or extraordinary circumstances warrant relief. Under 18 U.S.C. 3583(e), a sentencing court may terminate supervised release before its expiration after considering the 18 U.S.C. 3553(a) factors. The district court considered the section 3553(a) factors, Melvin’s conduct, and the interest of justice in reaching its conclusion that early termination was unwarranted but went on to require a showing of extraordinary or new circumstances. The court noted that the district court would likely act within the bounds of its discretion if it reached the same result on remand.
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