United States v. Morin, No. 23-2221 (8th Cir. 2024)
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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Nolan Ryan Morin, who had pleaded guilty to a false-statements charge, a class D felony, faced the revocation of his supervised release multiple times. After his initial violation of supervised release, he was sentenced to 12 months' imprisonment and 3 years of supervised release. After two more violations, his supervised release was revoked and he was sentenced to 18 months' and then 24 months' imprisonment, respectively.
Morin appealed his most recent 24-month revocation term of imprisonment, arguing that the "all or part" clause in 18 U.S.C. § 3583(e)(3), which governs the revocation of supervised release, requires a sentencing court to credit previous revocation terms of imprisonment up to a maximum of the term of supervised release authorized by statute for the underlying offense. In Morin's case, he claimed that the total length of all revocation imprisonment he may serve based on his false-statements conviction was capped at 3 years, and as he had already served 30 months on his first two revocations, the district court was only authorized to impose a maximum of 6 months on the present revocation.
The Eighth Circuit disagreed with Morin's interpretation. The court held that the "all or part" clause imposed a per-revocation limit and did not require the court to consider or aggregate prior revocation terms of imprisonment. Moreover, the court opined that the clause expanded the sentencing court's authority by removing the limitation that a prison term imposed could never be longer than the term of the revoked supervised release. Thus, the court affirmed the 24-month term of revocation imprisonment Morin received as it was authorized by statute.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge] Criminal case - Sentencing. The court rejects defendant's argument that the "all or part" provision of 18 U.S.C. Sec. 3583(e)(2) required the district court to aggregate his prior revocation sentences to determine the amount of time to which he could be sentenced in this revocation proceeding.
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