United States v. Helton - Supervised Release Modification Appeal

4th Circuit Daily Opinions

Filed March 30th, 2026

Detected March 31st, 2026

Summary

The Fourth Circuit affirmed the district court's orders denying Steven Russell Helton's motions to modify conditions of his supervised release under 18 U.S.C. § 3583(e)(2). The appeals (Nos. 24-4366 and 25-4014) were consolidated and decided in favor of the government. No abuse of discretion was found in the district court's denial of Helton's modification requests.

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What changed

The Fourth Circuit reviewed two consolidated appeals where defendant Steven Russell Helton challenged the district court's denial of his motions to modify the conditions of his supervised release under 18 U.S.C. § 3583(e)(2). The cases originated in the Southern District of West Virginia (Case No. 5:12-cr-00134-1) before Chief District Judge Frank W. Volk. Applying an abuse of discretion standard as articulated in United States v. Castellano, the appellate court affirmed both district court orders (dated July 2, 2024 and December 24, 2024).

This decision is binding only on the parties in the Fourth Circuit and does not create binding precedent. For practitioners, the ruling reinforces that § 3583(e)(2) motions for supervised release condition modifications face a high bar and that appellate review is deferential. Defendants seeking such modifications should ensure they present compelling factual grounds demonstrating abuse of discretion by the lower court.

Source document (simplified)

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4366

UNITED STATES OF AMERICA, Plaintiff - Appellee,

STEVEN RUSSELL HELTON, Defendant - Appellant.

No. 25-4014

UNITED STATES OF AMERICA, Plaintiff - Appellee,

STEVEN RUSSELL HELTON, Defendant - Appellant. Appeals from the United States District Court for the Southern District of West Virginia, at Beckley. Frank W. Volk, Chief District Judge. (5:12-cr-00134-1) Submitted: March 26, 2026 Decided: March 30, 2026

Before RICHARDSON and BERNER, Circuit Judges, and FLOYD, Senior Circuit Judge. Affirmed by unpublished per curiam opinion.

ON BRIEF: Wesley P. Page, Federal Public Defender, Jonathan D. Byrne, Appellate

Counsel, David R. Bungard, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Charleston, West Virginia, for Appellant. Moore Capito, United States Attorney, Jennifer Rada Herrald, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, West Virginia, for Appellant. Unpublished opinions are not binding precedent in this circuit.

PER CURIAM: In these consolidated cases, Steven Russell Helton appeals the district court’s orders denying his motions for a modification of the conditions of his supervised release, pursuant to 18 U.S.C. § 3583(e)(2). Upon review, we discern no abuse of discretion in the district court’s decisions. See United States v. Castellano, 60 F.4th 217, 223 (4th Cir. 2023) (providing standard of review for § 3583(e)(2) motion). Accordingly, we affirm the district court’s orders. United States v. Helton, No. 5:12-cr-00134-1 (S.D. W. Va. July 2, 2024; Dec. 24, 2024). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.

AFFIRMED