Background
Monica Renee Metcalf appealed a Northern District of Texas judgment revoking her supervised release. The district court imposed six months in prison followed by an additional term of supervised release.
For the first time on appeal, Metcalf argued that the mandatory-revocation provision in 18 U.S.C. § 3583(g) was unconstitutional under the Supreme Court’s decision in United States v. Haymond. She acknowledged, however, that the Fifth Circuit’s decision in United States v. Garner foreclosed her challenge.
The Court’s Holding
The Fifth Circuit held that summary affirmance was proper because Garner remained controlling circuit precedent and foreclosed Metcalf’s constitutional argument.
The court granted the government’s motion for summary affirmance and affirmed the district court’s judgment. It denied as moot the government’s alternative request for additional time to file a brief.
Key Takeaways
- Fifth Circuit precedent forecloses the argument that 18 U.S.C. § 3583(g) is unconstitutional under Haymond.
- A foreclosed appellate argument may be resolved through summary affirmance.
- The six-month prison sentence and additional supervised-release term remained in place.
Why It Matters
The decision confirms that Garner continues to control constitutional challenges to mandatory supervised-release revocation under § 3583(g) in the Fifth Circuit. Unless that precedent is displaced by the en banc court or the Supreme Court, similarly situated defendants cannot obtain relief from a Fifth Circuit panel on the same theory.