Reported / Citable
Background
Jonathan Edward Anderson was sentenced in August 2020 to 84 months in prison followed by five years of supervised release. His supervised-release term began on November 5, 2024.
In July 2026, a probation officer petitioned for a warrant based on alleged violations of Anderson’s supervised-release conditions, including positive methamphetamine tests. At the final revocation hearing, the government moved to dismiss allegations one and two, and Anderson pleaded true to allegation three. He consented to revocation and waived his right to object to the magistrate judge’s proposed findings and recommendations. The parties agreed to a proposed sentence of 21 months in prison with no further supervised release, but the formal recommendation did not address post-imprisonment supervision.
The Court’s Holding
Magistrate Judge Bill Davis recommended dismissing allegations one and two and revoking Anderson’s supervised release based on allegation three.
The magistrate judge further recommended committing Anderson to the Bureau of Prisons for 21 months, consecutive to any other term of imprisonment, and placing him at FCI Forrest City in Arkansas if appropriate. The report did not formally recommend whether Anderson should receive an additional term of supervised release after imprisonment.
Key Takeaways
- Anderson admitted allegation three and consented to revocation of his supervised release.
- The magistrate judge recommended dismissing the first two allegations and imposing 21 months of consecutive imprisonment based on the remaining allegation.
- Although the parties agreed that no supervised release should follow imprisonment, that disposition was not included in the report’s enumerated recommendations.
Why It Matters
The report distinguishes between the sentence discussed and accepted by the parties at the hearing and the relief formally recommended to the district judge. Any subsequent ruling must be assessed against the report’s actual enumerated recommendations, which did not resolve post-imprisonment supervised release.