United States v. Ponce, No. 21-30009 (9th Cir. 2022)Annotate this Case
Ponce pleaded guilty to the distribution of methamphetamine in 2015. He was sentenced to the mandatory minimum term of 60 months’ imprisonment plus 48 months of supervised release. While in custody, Ponce pursued his rehabilitation with diligence and graduated from the Bureau of Prison’s nine-month intensive Residential Drug Abuse Program. Ponce began his term of supervised release in August 2018. In October 2020, Ponce sought early termination of supervised release, citing his regular involvement with his church, commitment to his family responsibilities, and stable employment. Ponce had married and early termination would improve his family’s housing options.
The Ninth Circuit vacated the denial of Ponce’s motion. The correct legal standard for deciding a motion to terminate supervised release appears in 18 U.S.C. 3583(e), whose expansive phrases “conduct of the defendant” and “interest of justice” make clear that a district court enjoys discretion to consider a wide range of circumstances when determining whether to grant early termination. The text of section 3583(e) does not support a legal standard that categorically requires a petitioner to demonstrate undue hardship. Because it was unclear whether the district court applied an improper “blanket rule” that early termination requires exceptional circumstances, the court remanded for the district court to reconsider Ponce’s motion and clarify the standard applied.