Consecutive Sentences for Supervised Release Violations

United States v. Francis T. Deutsch, Case No. 02-3235 (04/12/2005): Deutsch was sentenced on multiple counts, with a term of supervised release attached to each count. After his release from prison, he violated the terms of his release. His guidelines range for the violation was 12 to 18 months. The district court imposed consecutive prison terms for a total of 61 months.

Whether the judge had the power to impose consecutive sentences for a violation of supervised release was a matter of first impression in this Circuit, and the Court joined other Circuits in affirming the district judge's authority to impose consecutive sentences.