Background
Lucas Monrajas appealed from a judgment of the U.S. District Court for the Northern District of Texas, USDC No. 3:24-CR-527-1, that revoked his term of supervised release and imposed a sentence of 10 months of imprisonment. The Fifth Circuit placed the case on its summary calendar, and the per curiam opinion—issued by a panel of Circuit Judges King, Higginson, and Douglas—was expressly designated as not for publication under 5th Cir. R. 47.5.
For the first time on appeal, Monrajas raised a constitutional challenge to 18 U.S.C. § 3583(g), the statute governing mandatory revocation of supervised release in certain circumstances. He argued that the provision is unconstitutional in light of the Supreme Court’s decision in United States v. Haymond, 588 U.S. 634 (2019). According to Monrajas, § 3583(g) runs afoul of constitutional guarantees because it requires a court to revoke a term of supervised release and impose imprisonment without affording the defendant the constitutionally guaranteed right to a jury trial or requiring that the relevant facts be proven beyond a reasonable doubt.
Rather than proceed through full briefing, the Government moved for summary affirmance. Monrajas did not oppose that motion. The procedural posture is significant: because the constitutional argument was raised for the first time on appeal, the district court had no occasion to consider it below, and the Fifth Circuit was asked to resolve the appeal on an expedited, summary basis.
The Court’s Holding
The Fifth Circuit granted the Government’s motion for summary affirmance and affirmed the district court’s judgment. The court’s reasoning was brief and rested squarely on controlling circuit precedent. The opinion noted that Monrajas “correctly concedes that his argument is foreclosed,” citing United States v. Garner, 969 F.3d 550, 551–53 (5th Cir. 2020). In Garner, the Fifth Circuit had already addressed and rejected a comparable constitutional challenge to § 3583(g) premised on Haymond, and that prior panel decision bound the court in this case.
The court applied the established standard for summary affirmance, quoting Groendyke Transportation, Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969): summary affirmance is appropriate where the Government’s position “is clearly right as a matter of law so that there can be no substantial question as to the outcome of the case.” Because Garner foreclosed Monrajas’s constitutional argument, the court concluded that this standard was satisfied and that full briefing was unnecessary.
The complete disposition was threefold. First, the Government’s motion for summary affirmance was granted. Second, the Government’s alternative motion for an extension of time to file a brief was denied as unnecessary given the summary disposition. Third, the district court’s judgment revoking supervised release and imposing the 10-month term of imprisonment was affirmed.
Key Takeaways
- The Fifth Circuit summarily affirmed the revocation of Lucas Monrajas’s supervised release and the imposition of a 10-month prison sentence, resolving the appeal without full briefing.
- Monrajas argued for the first time on appeal that 18 U.S.C. § 3583(g) is unconstitutional under United States v. Haymond, 588 U.S. 634 (2019), because it mandates revocation and imprisonment without a jury trial or proof beyond a reasonable doubt.
- The court held that the argument was foreclosed by United States v. Garner, 969 F.3d 550, 551–53 (5th Cir. 2020), and Monrajas himself conceded that his position was foreclosed by that precedent.
- Summary affirmance was granted under the Groendyke Transportation standard because the Government’s position was clearly right as a matter of law and no substantial question existed as to the outcome.
- The Government’s alternative motion for an extension of time to file a brief was denied, and the district court’s judgment was affirmed in full.
Why It Matters
This unpublished per curiam decision reinforces the Fifth Circuit’s settled position that constitutional challenges to 18 U.S.C. § 3583(g) based on Haymond are foreclosed by circuit precedent, specifically United States v. Garner. Practitioners in the Fifth Circuit should recognize that raising this argument—particularly for the first time on appeal—is unlikely to succeed absent en banc or Supreme Court intervention. The case also illustrates the court’s willingness to use its summary-calendar procedures to dispose of appeals efficiently when the outcome is controlled by clearly established precedent and the appellant concedes as much.
The decision further demonstrates the practical consequences of failing to preserve constitutional objections in the district court. Although the opinion does not articulate a forfeiture analysis, the fact that the argument was raised for the first time on appeal and was met with an unopposed motion for summary affirmance underscores the importance of raising constitutional challenges at the earliest opportunity. For defense attorneys handling supervised-release revocation proceedings, Garner remains the controlling obstacle to any Haymond-based attack on § 3583(g) within this circuit.