United States v. Brown, No. 15-3496 (7th Cir. 2016)
Annotate this CaseIn 2012 Brown pled guilty to failing to register as a sex offender, 18 U.S.C. 2250(a), and was sentenced to 18 months in prison followed by 60 months of supervised release. Within months of being released from prison, Brown was arrested for violating the Illinois sex-offender registration law, 730 ILCS 150/3(a). He pled guilty and was sentenced to 18 months in state prison. Brown’s federal probation officer then petitioned the district court to revoke his supervised release, 18 U.S.C. 3583(e)(3), citing Brown’s state case and his failure to submit timely supervision reports on five occasions. Brown admitted the allegations. The district court revoked his supervised release, ordered him to serve an additional 12 months in prison (consecutive to his new state sentence) and imposed a 10-year term of supervised release. Brown filed a notice of appeal, but his appointed attorney asserted that the appeal was frivolous and sought to withdraw under Anders v. California. The Seventh Circuit granted the Anders motion and dismissed. There is no constitutional right to counsel in a revocation proceeding when the defendant admits violating the conditions of his supervision and neither challenges the appropriateness of revocation nor asserts substantial and complex grounds in mitigation.
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