United States v. Lee, No. 14-2010 (7th Cir. 2015)
Annotate this CaseWhile Lee was on supervised release, his probation officer learned that he had assaulted his girlfriend, Pulliam, with a small souvenir baseball bat. The court issued a warrant for Lee’s arrest and initiated proceedings to revoke his supervised release. Law enforcement and medical personnel who interviewed or treated Pulliam testified. Pulliam had told each that Lee was the perpetrator. Pulliam took the stand, recanted, and said that she had made up a story because she was mad at Lee. She explained that she fell down the stairs. The court concluded that Lee had committed assault with a deadly weapon, revoked supervised release, and imposed a four-year term of imprisonment. Although he did not raise the argument below, Lee argued on appeal that he was denied due process under both the Fifth Amendment and Federal Rule of Criminal Procedure 32.1 because he did not receive adequate written notice of the precise crime that led to the revocation. The Seventh Circuit affirmed, declining to adopt a per se rule that only citation to a specific statute provides sufficient written notice of the alleged violation. Only the Ninth Circuit has adopted such a rule. Supervised release revocation hearings are not criminal prosecutions; the full panoply of rights does not extend to them.
The court issued a subsequent related opinion or order on July 30, 2015.
The court issued a subsequent related opinion or order on July 30, 2015.
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