Facts
- Andre Ralph Haymond was convicted by a jury of possessing child pornography, an offense carrying a prison range of 0 to 10 years.
- The district court sentenced him to 38 months’ imprisonment followed by 10 years of supervised release.
- After he completed the custodial term, probation officers searched his phone and found 59 images believed to be child pornography.
- At a supervised-release revocation hearing, the district judge (without a jury) found by a preponderance of the evidence that Haymond knowingly possessed child pornography.
- Under 18 U.S.C. § 3583(e)(3), the judge otherwise could have imposed up to 2 years’ additional imprisonment for the violation.
- Because the violation involved an offense listed in 18 U.S.C. § 3583(k), the statute required a 5-year mandatory minimum term (and authorized up to life) based solely on the judge’s revocation findings.
Issues
- Whether 18 U.S.C. § 3583(k), as applied to require a 5-year mandatory minimum based on judge-found facts proved by a preponderance at a supervised-release revocation hearing, violates the Fifth and Sixth Amendments.
- Whether revocation under § 3583(k) is sufficiently like punishment for a new criminal offense to require jury findings beyond a reasonable doubt for facts that trigger the mandatory minimum.
Decision
- The Supreme Court vacated the Tenth Circuit’s judgment and remanded.
- No single majority rationale commanded five votes.
- A four-Justice plurality concluded that applying § 3583(k) to impose a new mandatory minimum based on judge-found facts violated the jury-trial right and the beyond-a-reasonable-doubt requirement.
- Justice Breyer concurred in the judgment on narrower grounds; his concurrence provided the controlling rationale.
- The dissent would have upheld § 3583(k) and warned against extending jury-trial requirements to supervised-release revocations.
Legal Principles
- Under the controlling concurrence, a supervised-release revocation scheme can trigger Fifth and Sixth Amendment protections when it operates less like ordinary revocation and more like punishment for a new criminal offense.
- Features supporting that conclusion include: (1) coverage limited to a discrete set of criminal offenses, (2) imposition of a substantial mandatory minimum term of imprisonment, and (3) mandatory punishment triggered by judge-found facts proved only by a preponderance of the evidence.
- The decision does not broadly constitutionalize supervised-release revocation proceedings or invalidate ordinary revocations under § 3583(e).
Conclusion
The Court held that § 3583(k) was unconstitutional as applied because it required a new, substantial mandatory minimum prison term based on judge-found facts at revocation, functioning like punishment for a new offense without the jury-trial and proof-beyond-a-reasonable-doubt protections required by the Fifth and Sixth Amendments.