United States v. Patlan, No. 21-1500 (7th Cir. 2022)
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In 2012, Patlan pled guilty to conspiracy to distribute controlled substances. He began supervised release in April 2017. Because of violations, in January 2019, the court added six months of home confinement. After additional violations district court revoked his supervision and sentenced him to 18 months’ imprisonment plus three years of supervised release, including six months of home confinement. Patlan began his second period of supervised release in September 2020. In December 2020, he tested positive for drugs; in January he committed domestic battery. The Probation Office classified the drug possession as a Grade B violation, calculating his guidelines range as 18-24 months of imprisonment. Following Patlan’s concession of guilt, the court entertained Patlan’s “policy objection,” then sentenced Patlan to 18 months’ imprisonment (including 61 days of home confinement remaining when his supervision was revoked), plus 24 months of supervised release.
The Seventh Circuit affirmed, rejecting arguments that the district court erred when it failed to recognize that it had the discretion to reject the inference that he possessed controlled substances from a positive drug test and to treat a failed drug screening as a Grade C violation, failed to provide justifications for the six‐month term of home confinement, and failed to pronounce that condition orally during the hearing.
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