Reported / Citable
Background
Christian Anthony Skall was serving a three-year term of supervised release following his conviction for conspiracy to distribute methamphetamine. His original 240-month prison sentence was reduced to 170 months through compassionate release, and he began supervision in May 2025. Jurisdiction was transferred to the Eastern District of Texas in January 2026.
Probation sought revocation, alleging that Skall used cocaine on several occasions and failed to report for multiple requested drug tests. At the final revocation hearing, Skall agreed to plead true to the cocaine-use allegation and jointly requested a sentence of 12 months and one day in prison, with no additional supervised release.
The Court’s Holding
The report and recommendation found that Skall knowingly and voluntarily waived a revocation hearing and pleaded true to the cocaine-use allegation. By a preponderance of the evidence, the report found the allegation true and classified the conduct as a Grade B supervised-release violation.
The magistrate judge recommended that the district court accept the plea, revoke Skall’s supervised release, and impose 12 months and one day of imprisonment with no further supervised release. It also recommended reimposing previously ordered monetary penalties, crediting payments toward outstanding balances, and requesting Bureau of Prisons designation to FCI Texarkana.
Key Takeaways
- The disposition is a report and recommendation, not a final revocation judgment by the district judge.
- Skall admitted the cocaine-use allegation; the remaining allegation concerning missed drug tests was not the basis of his plea.
- Both parties waived objections to the report and recommendation, and Skall waived his right to be present and allocute before sentencing.
Why It Matters
The recommendation illustrates that an admitted supervised-release violation can support revocation and a custodial sentence even where the parties jointly propose the disposition. It also reflects an individualized determination that further supervision was not warranted after the proposed prison term.