Carroll v. Martin, No. 12-3332 (7th Cir. 2014)
Annotate this CaseIn 1999 Carroll was convicted in Illinois of aggravated sexual assault and sentenced to 28 years in prison. He obtained post-conviction relief and was resentenced, to 26 years. Neither the judge at sentencing nor the official copy of the judgment mentioned supervised release. Carroll learned that a three-year term of supervised release was required by statute, 730 ILCS 5/5-8-1(d). He filed a federal petition for habeas corpus, 28 U.S.C. 2254, asking the court to order him excused from having to serve supervised release, arguing that to impose punishment in excess of the sentence delivered by a judge violates clearly established federal law. Later Carroll indicated that what he really wanted was to have his prison term reduced to 23 years so that the aggregate time in prison and on supervised release would be 26 years. The district judge held that Carroll must serve 26 years in prison and three years on supervised release. The Seventh Circuit affirmed; any error was merely a departure from a customary but not a mandatory procedure. If ordered to resentence Carroll, the Illinois court would impose an identical sentence except that it would list the statutory conditions and duration of mandatory supervised release. Failure to mention supervised release in Carroll’s sentence did not deprive him of life, liberty, or property.
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