Bowers

I. Factual and Procedural Background

In 2019, pursuant to a guilty plea, Bowers was convicted of possession of heroin with intent to distribute in violation of 21 U.S.C. § 841(a)(1), (b)(C). He was sentenced to 36 months imprisonment to be followed by three years of supervised release. In 2023, after Bowers completed his prison time and while on supervised release, his probation officer filed two separate petitions with the district court alleging that Bowers violated his supervised release by committing two state crimes: (1) fourth-degree assault, and (2) violating a protective order. The probation officer recommended the district court revoke Bowers’ supervised release. While the revocation hearing was pending, Bowers resolved his criminal charges in state court by entering a deferral agreement without admitting to guilt.

1 We dispose of Bowers’ other claims in a concurrently filed memorandum disposition.

USA V. BOWERS

Subsequently, the district court held a supervised release revocation hearing. During the hearing, Bowers invoked his right to a jury trial. 2 The district court denied Bowers’ request and proceeded with the revocation hearing…