United States v. Goodwin — Fourth Circuit upheld denial of early termination of supervised release

Case
United States of America v. Leroy Goodwin, a/k/a Chip
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
KING; HEYTENS; BENJAMIN
Date Decided
September 1, 2026
Docket No.
26-6471
Topics
Supervised Release; Early Termination; Criminal Appeals
Source
Read the full opinion

Background

Leroy Goodwin moved in the U.S. District Court for the District of South Carolina for early termination of his supervised release. Senior District Judge Cameron McGowan Currie denied the motion on April 7, 2026.

Goodwin, proceeding without counsel, appealed the denial to the Fourth Circuit. The appellate court submitted the case for decision without oral argument on August 27, 2026.

The Court’s Holding

The Fourth Circuit affirmed the district court’s order denying early termination of Goodwin’s supervised release. After reviewing the record, the panel found no reversible error.

The court issued an unpublished per curiam opinion and did not provide further analysis of the district court’s reasoning. It concluded that oral argument was unnecessary because the written materials adequately presented the facts and legal contentions and argument would not aid the decisional process.

Key Takeaways

  • The district court’s denial of early termination of Goodwin’s supervised release remains in effect.
  • The Fourth Circuit found no reversible error in the record.
  • The opinion is unpublished and is not binding precedent in the Fourth Circuit.

Why It Matters

The decision illustrates that a denial of early termination of supervised release will be affirmed when the appellate record reveals no reversible error. Because the Fourth Circuit offered no substantive analysis, the opinion provides limited guidance about the circumstances that warrant early termination.

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