Reported / Citable
Background
In August 2021, Anthony Gregory Trent Jr. was sentenced by U.S. District Judge Alan D. Albright to 63 months in prison followed by a three-year term of supervised release for being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). His sentence included special conditions requiring mental health treatment, substance abuse treatment, and compliance with search conditions.
Trent Jr. began his supervised release on July 3, 2025. Within weeks, he tested positive for amphetamine/methamphetamine. No revocation action was taken at that time. Then, on November 9, 2025, Killeen Police Department arrested him for driving while intoxicated and possession of a controlled substance after he failed a field sobriety test and officers discovered a substance in his vehicle that tested positive for methamphetamine.
On November 14, 2025, the U.S. Probation Office filed a petition for revocation, alleging Trent Jr. violated his mandatory supervision conditions by committing another state crime. At a hearing held on June 9, 2026, Trent Jr. entered a plea of no contest to the single alleged violation, and the magistrate judge found a sufficient factual basis to support that plea.
The Court’s Holding
U.S. Magistrate Judge Dan N. MacLemore issued a Report and Recommendation finding that Trent Jr. knowingly, voluntarily, and intelligently entered his no-contest plea, that he was competent throughout the proceedings, and that the petition’s factual basis supported the violation. The magistrate found Trent Jr. violated Mandatory Condition Number 1 of his supervision by committing another state or local crime during his term of supervised release.
The magistrate recommended that the district judge revoke Trent Jr.’s supervised release and impose an 18-month term of imprisonment — including credit for any time served since his arrest — to run consecutively to any sentence imposed in the related state court case. The recommendation further called for no additional period of supervised release to follow the imprisonment term.
Key Takeaways
- A positive drug test early in supervision, left unaddressed, did not prevent a later revocation petition when the defendant was subsequently arrested on new drug and DWI charges.
- The magistrate recommended consecutive — not concurrent — federal imprisonment relative to the anticipated state sentence, a factor that will significantly affect Trent Jr.’s total time incarcerated.
- No further supervised release was recommended, signaling the court’s view that additional community supervision is unwarranted given Trent Jr.’s conduct shortly after release.
- Parties have 14 days to file objections to the Report and Recommendation; failure to object waives de novo review by the district judge and forecloses most appellate review.
Why It Matters
This case illustrates how quickly supervised release can unravel after a federal sentence is served and how courts respond to early violations. The decision not to act on Trent Jr.’s initial positive drug test did not insulate him from revocation when new criminal conduct followed; the subsequent arrest provided independent grounds for the petition and ultimately drove the recommendation for an 18-month consecutive term.
For practitioners, the recommendation of consecutive federal imprisonment alongside a pending state sentence — combined with no tail of supervised release — reflects a punitive posture the district court may adopt when a defendant commits new offenses almost immediately upon commencing supervision. Defense counsel should be attentive to the objection deadline and the limited appellate options if no timely objection is filed.