Carney — Fourth Circuit upheld supervised-release revocation sentence

Case
United States of America v. Alfonso Carney
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
WILKINSON (Ronald Reagan, 1984); HEYTENS (Joseph R. Biden, 2021)
Date Decided
July 20, 2026
Docket No.
25-4073
Topics
Supervised Release, Revocation, Sentencing
Source
Read the full opinion

Background

Alfonso Carney repeatedly violated the conditions of his supervised release. The U.S. District Court for the Eastern District of Virginia therefore revoked his supervised release.

The district court sentenced Carney to time served, followed by two additional years of supervision. Carney appealed, arguing that the revocation sentence was plainly unreasonable.

The Court’s Holding

In an unpublished per curiam opinion, the Fourth Circuit affirmed the district court’s judgment. After reviewing the record, the court concluded that there was no reversible error in Carney’s revocation sentence.

The court did not provide a more detailed analysis of Carney’s challenge. It also dispensed with oral argument because the written materials adequately presented the facts and legal contentions and argument would not aid the decisional process.

Key Takeaways

  • The Fourth Circuit upheld the revocation of Carney’s supervised release after repeated violations of his supervision conditions.
  • The court found no reversible error in the sentence of time served followed by two years of further supervision.
  • The unpublished per curiam opinion is not binding precedent in the Fourth Circuit.

Why It Matters

The decision leaves Carney’s revocation sentence intact and illustrates the difficulty of overturning such a sentence under the plainly unreasonable standard when the appellate record reveals no reversible error.

Because the opinion is unpublished and offers only a summary disposition, its value as guidance for future supervised-release cases is limited.

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