United States v. LeSean Roberts - Supervised Release Termination
Summary
The Sixth Circuit vacated the District Court for the Northern District of Ohio's denial of LeSean Roberts's motion to terminate supervised release. The appellate court found the district court failed to clearly demonstrate consideration of the required 18 U.S.C. § 3553(a) factors in denying the motion. The case (No. 25-3789) has been remanded for further proceedings.
What changed
The Sixth Circuit reversed the district court's denial of LeSean Roberts's second motion to terminate supervised release. Roberts, convicted of drug offenses nearly two decades ago, had his life sentence commuted to 240 months by the President in 2016, then further reduced to time served plus eight years of supervised release. After Roberts served 180 months, the district court denied his motion to terminate supervision, memorializing the denial only through a marginal entry and a probation report. The appellate panel found this procedural record insufficient, as it did not demonstrate the court considered the statutory factors under 18 U.S.C. § 3553(a) required for supervised release termination decisions.\n\nOn remand, the district court must more thoroughly document its consideration of the § 3553(a) factors when ruling on Roberts's termination motion. Defense counsel and probation officers should ensure that future supervised release termination motions include a complete record demonstrating the court's evaluation of all relevant statutory considerations, including the nature of the offense, Roberts's history and characteristics, and the need for continued supervision.
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April 2, 2026 Get Citation Alerts Download PDF Add Note
United States v. LeSean Roberts
Court of Appeals for the Sixth Circuit
- Citations: None known
- Docket Number: 25-3789
- Precedential Status: Non-Precedential
- Panel: Eric L. Clay, David William McKeague, John Baylor Nalbandian
Judges: Eric L. Clay; David W. McKeague; John B. Nalbandian
Combined Opinion
NOT RECOMMENDED FOR PUBLICATION
File Name: 26a0155n.06
Case No. 25-3789
FILED
UNITED STATES COURT OF APPEALS Apr 02, 2026
FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk
)
UNITED STATES OF AMERICA,
)
Plaintiff-Appellee, ) ON APPEAL FROM THE
) UNITED STATES DISTRICT
v. ) COURT FOR THE NORTHERN
) DISTRICT OF OHIO
LESEAN ROBERTS, )
Defendant-Appellant. )
) OPINION
Before: CLAY, McKEAGUE, and NALBANDIAN, Circuit Judges.
McKEAGUE, Circuit Judge. LeSean Roberts moved to terminate his supervised release.
Because the record does not make clear that the district court considered the relevant 18 U.S.C.
§ 3553 (a) factors in denying Roberts’s motion, we VACATE the district court’s order and
REMAND.
I.
Nearly two decades ago, LeSean Roberts was convicted of drug offenses. At the time,
based on Roberts’s criminal history, the district court was required to impose a mandatory term of
life imprisonment. But in 2016, the President commuted Roberts’s sentence to 240 months. And
then, after Roberts had served 180 months’ imprisonment, the district court reduced his custodial
sentence to time served and imposed an eight-year period of supervised release.
Since his release, Roberts has twice moved to end his supervision. The district court denied
his first motion, which came just a year-and-a-half after his release. So, Roberts renewed his
No. 25-3789, United States v. Roberts
request when his supervision term neared its halfway point. But the district court denied that
request too.
A pair of docket entries memorialize the district court’s more recent ruling. The first is a
marginal entry on Roberts’s motion, with an “x” to indicate that the request was denied. The
second consists of a supervision report prepared by the probation office, detailing Roberts’s
compliance with supervision, and reciting the relevant 18 U.S.C. § 3553 (a) factors. Looking to
Roberts’s history and characteristics, the report recommended denying Roberts’s motion because
“he is a career offender.” R. 243, PageID 2096. The district court refiled the supervision report in
its entirety and checked a box on the last page indicating that Roberts’s request was denied.
Roberts appealed, arguing that the district court abused its discretion in denying his motion.
The government agrees.
II.
A district court may “terminate a term of supervised release and discharge the defendant
released at any time after the expiration of one year of supervised release . . . if it is satisfied that
such action is warranted by the conduct of the defendant released and the interest of justice.”
18 U.S.C. § 3583 (e)(1). But, in exercising that discretion, “the record must demonstrate that the
district court considered the relevant § 3553(a) factors before denying an early termination
motion.” United States v. Tavarez, 141 F.4th 750, 758 (6th Cir. 2025); see 18 U.S.C. § 3583 (e).
That’s because a district court “abuses its discretion in denying a motion for sentence reduction
when the record as a whole fails to satisfy us that the district court considered the parties’
arguments and had a reasoned basis for exercising its own legal decisionmaking authority.”
Tavarez, 141 F.4th at 757 (citation modified).
-2-
No. 25-3789, United States v. Roberts
Against that backdrop, Tavarez makes clear that a district court cannot deny a defendant’s
motion for early termination of his supervised release with only a checkmark. Id. at 758. Here,
across two orders, the district court denied Roberts’s motion by marking an “x” on a line. In doing
so, it did not mention § 3553(a) or offer any measure of additional reasoning. Put differently,
the district court provided “no indication” that it considered the relevant sentencing factors. Id.
at 759. The government concedes as much. See Appellee’s Br. at 6. And we have consistently
deemed similar orders insufficient. See, e.g., Tavarez, 141 F.4th at 759; United States v. Morgan,
No. 25-3714, 2026 WL 249619, at *1 (6th Cir. Jan. 27, 2026); United States v. Flowers, No.
25-3523, 2025 WL 3525260, at *1 (6th Cir. Dec. 4, 2025); United States v. Evans, No. 25-5118,
2025 WL 2486607, at *1-2 (6th Cir. Aug. 26, 2025).
True, the supervision report includes a recitation of the § 3553(a) factors. Cf. Tavarez, 141
F.4th at 758 (recognizing that when there was “no mention of the factors anywhere” in a
supervision report, a similar order did “not show that the district court reasoned through Tavarez’s
arguments or considered the relevant § 3553(a) factors”). Even still, the district court’s orders
contain no language indicating it considered the relevant sentencing factors. See Morgan, 2026
WL 249619, at *1 (Bush, J., concurring). Nor do the orders “explicitly” adopt the supervision
report’s analysis. Id. While we have recognized (in other contexts) that a barebones order may
sometimes be sufficient, there must be at least some indication in the record as to how the district
court considered the § 3553(a) factors. See, e.g., United States v. Davis-Malone, 128 F.4th 829,
834 (6th Cir.) (citing Chavez-Meza v. United States, 585 U.S. 109, 113 (2018)), cert. denied, 145
S. Ct. 2827 (2025). There is nothing of the sort here. Without more, the district court’s checkmark
denial does not allow us to “discern from the record how or why denying the motion to terminate
-3-
No. 25-3789, United States v. Roberts
comported with consideration of the relevant § 3553(a) factors.” Tavarez, 141 F.4th at 758–59
(citation modified).
The district court’s omission of any analysis leads to other problems as well. In reciting
the § 3553(a) factors, the supervision report referred to Roberts as a career offender. But, as
Roberts points out, the district court previously concluded that he was improperly classified as a
career offender at sentencing (although, at the time, that error had no impact, given the statutory
minimum term). See United States v. Montanez, 442 F.3d 485, 494 (6th Cir. 2006). Because of
the district court’s lack of analysis, we cannot say how, or even if, that erroneous offender
classification factored into the decision to deny Roberts’s motion.
III.
All told, we VACATE the district court’s order denying Roberts’s motion to terminate his
supervised release and REMAND consistent with Tavarez.
-4-
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