Background
Terrance Morgan began a three-year term of supervised release in December 2022 after serving a federal prison sentence for firearm and drug-trafficking offenses. He later admitted numerous violations, including positive drug tests, failure to attend treatment, failure to report to or communicate with probation, failure to provide proof of employment or an approved alternative, and a state conviction for battery upon a dating partner and simple battery.
After Morgan was arrested in October 2025, a magistrate judge released him to a 30-day inpatient treatment program followed by home detention with location monitoring. Morgan completed the program and asked the district court to postpone his revocation hearing so he could demonstrate continued compliance. The court declined, revoked supervised release, and imposed eight months in prison followed by 24 months of supervised release.
The Court’s Holding
The Fifth Circuit affirmed. It held that the district court adequately considered the drug-treatment exception to mandatory revocation under 18 U.S.C. § 3583(d). The district court knew Morgan had completed inpatient treatment, heard his argument that treatment made imprisonment unnecessary, and correctly described the governing law. It was not required to recite a checklist or expressly repeat Morgan’s treatment evidence; its decision to revoke implicitly rejected the exception.
The appellate court also held that the district court did not rely on a clearly erroneous view of the facts. The judge was entitled to weigh Morgan’s extended pattern of violations more heavily than his comparatively brief period in treatment and on location monitoring. The record showed particular concern about Morgan’s progression from drug violations to violence, including his battery convictions.
Although the district court mistakenly used the 2024 Sentencing Guidelines instead of the 2025 version in effect at the hearing, the error was harmless because the relevant provisions did not materially differ and the mistake did not affect Morgan’s substantial rights. The denial of a continuance likewise was not an abuse of discretion because Morgan showed no specific or compelling prejudice, and he did not challenge the length of his revocation sentence.
Key Takeaways
- A district court may implicitly consider and reject the statutory drug-treatment exception to mandatory supervised-release revocation; no checklist or special wording is required.
- Successful completion of treatment does not compel application of the exception when the defendant has an extensive history of violations and the court finds treatment insufficient.
- Use of an outdated Guidelines edition is harmless when the applicable provisions do not materially differ and the error does not affect substantial rights.
Why It Matters
The decision reinforces the substantial discretion district courts retain when deciding whether treatment warrants an exception to otherwise mandatory revocation. A record showing that the court knew of the treatment evidence and heard the defendant’s argument may be enough to establish proper consideration, even without an express finding addressing each point.
The opinion also underscores that procedural errors during revocation proceedings require a showing of prejudice. An incorrect Guidelines edition or denial of additional time will not justify reversal when neither affected the revocation decision or sentence.