United States v. Angelo Earl

I. Background

Defendant-appellant, Angelo Earl, appeals the trial court’s finding that he violated a condition of his supervised release. Defendant argues the trial court lacked jurisdiction to revoke his term of release. For the reasons discussed below, the trial court retained jurisdiction over defendant’s revocation hearing. We therefore affirm the trial court’s order revoking his super vised release and imposing additional conditions on defendant.

Defendant pled guilty to four drug offenses, including attempting to sell sixty-three grams of cocaine to an undercover police officer. On January 18, 2000, the trial court sentenced him to 121 months’ imprisonment and five years’ supervised release. Defendant officially began supervised release on June 10, 2007. Sometime before then, the Bureau of Prisons (BOP) had placed defendant at a halfway house. Defendant succeeded at the halfway house, and the BOP thereafter placed him in home confinement.

On February 9, 2012, the probation officer filed a petition seeking to revoke defendant’s supervised release, alleging he violated two of his conditions of release. On February 28, 2012, the trial court held a revocation…