Unreported / Non-Citable
Background
Noah Adam England appealed after the Northern District of Texas revoked his supervised release and sentenced him to 11 months in prison followed by an additional term of supervised release.
For the first time on appeal, England argued that the mandatory-revocation provision in 18 U.S.C. § 3583(g) is unconstitutional under United States v. Haymond, 588 U.S. 634 (2019). He acknowledged, however, that Fifth Circuit precedent foreclosed his argument.
The Court’s Holding
The Fifth Circuit held that its decision in United States v. Garner, 969 F.3d 550 (5th Cir. 2020), foreclosed England’s constitutional challenge to § 3583(g). Because controlling precedent resolved the issue, the court concluded that summary affirmance was proper.
The court granted the Government’s motion for summary affirmance and affirmed the district court’s judgment. It denied the Government’s alternative motion for additional time to file a brief.
Key Takeaways
- Fifth Circuit precedent continues to foreclose the argument that 18 U.S.C. § 3583(g) is unconstitutional under Haymond.
- The court summarily affirmed England’s supervised-release revocation and resulting sentence.
- The opinion was issued per curiam on the summary calendar and was not designated for publication.
Why It Matters
The decision confirms that, absent contrary en banc or Supreme Court authority, defendants in the Fifth Circuit cannot obtain relief on a Haymond-based constitutional challenge to § 3583(g). It also illustrates that the court may resolve an appeal through summary affirmance when binding precedent squarely forecloses the appellant’s position.