The United States Court of Appeals for the Third Circuit ruled Friday in a precedential opinion that contrary to impressions left by inartfully written "non-precedential decisions," district courts do not need to find new, unforeseen, extraordinary or exceptional circumstances to grant motions for early termination of supervised release. The Court reversed a New Jersey federal district court's denial of a motion to terminate supervised release because the defendant did not show that an exceptional circumstance warranted granting his request,.
A district court need not find that “an exceptional, extraordinary, new, or unforeseen circumstance warrants early termination of a term of supervised release” before granting such motions. "This requirement finds no support in the statutory text." "We therefore hold that a district court need not find that an exceptional, extraordinary, new, or unforeseen circumstance warrants early termination of a term of supervised release before granting a motion under 18 U.S.C. § 3583(e)(1)."
The defendant filed the motion because his "overall adjustment to supervision has been excellent. He is crime-free, incident-free, and is steadily employed in not just one but two jobs," the brief said. "He has completed 21 months of his three-year supervision term and represents no danger to the public. No need is served by continuing his supervision." Prosecutors opposed ther request, arguing to the court that the defendant "fails to set forth any extenuating, unforeseen, or extraordinary circumstances warranting early termination." The district court adopted the government's position and the standard in denying the motion.
The Circuit acknowledged the lower court "misapprehended the applicable legal standard because of language" in its previous decisions.
Following Friday's Circuit opinion, the district court issued an order terminating the defendant's supervised release. The district court stated it is "of the opinion that the defendant is well on his way to rehabilitation."