United States v. Block

CourtCourt of Appeals for the Tenth Circuit
DecidedJuly 29, 2025
Docket24-6243
StatusUnpublished

This text of United States v. Block (United States v. Block) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Block, (10th Cir. 2025).

Opinion

Appellate Case: 24-6243 Document: 35-1 Date Filed: 07/29/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT July 29, 2025 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-6243 (D.C. No. 5:18-CR-00206-R-1) AUSTIN JAY BLOCK, IV, (W.D. Okla.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT * _________________________________

Before BACHARACH, MORITZ, and ROSSMAN, Circuit Judges. _________________________________

Austin Block appeals the district court’s order revoking his term of supervised

release and sentencing him to 12 months’ imprisonment. Defense counsel has filed an

Anders brief and moved to withdraw as counsel. See Anders v. California, 386 U.S.

738, 744 (1967) (stating that if after “conscientious examination” of record, counsel

finds appeal “wholly frivolous,” then counsel may move to withdraw and

contemporaneously file “a brief referring to anything in the record that might

After examining the briefs and appellate record, this panel has determined *

unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. But it may be cited for its persuasive value. Fed. R. App. P. 32.1(a); 10th Cir. R. 32.1(A). Appellate Case: 24-6243 Document: 35-1 Date Filed: 07/29/2025 Page: 2

arguably support the appeal”). Block did not file a pro se response, and the

government declined to file a brief. We have reviewed the Anders brief and the

record to determine whether Block’s appeal is wholly frivolous. See United States v.

Calderon, 428 F.3d 928, 930 (10th Cir. 2005). Because we conclude that it is, we

dismiss the appeal and grant defense counsel’s motion to withdraw. See Anders, 386

U.S. at 744.

Background

In May 2019, the district court sentenced Block to 60 months in prison and

three years of supervised release for being a felon in possession of a firearm. Block

began serving this term of supervised release in January 2023. In February 2024,

Block violated its terms by failing to follow a probation officer’s directive to relocate

to approved housing, associating with a felon, submitting either diluted or positive

drug tests, and failing to report for drug testing. 1 At Block’s revocation hearing in

March, a probation officer testified that Block had relapsed on methamphetamine and

recommended that Block go to residential drug treatment. The district court

continued the hearing for 180 days to allow Block to enter treatment.

In May 2024, Block again violated the terms of his supervised release “when

he was unsuccessfully terminated from residential treatment due to rule violations.”

R. vol. 1, 22. At the resulting revocation hearing, the probation officer testified that

1 Block stipulated to all these violations, except for one instance of associating with a felon. The government declined to pursue this contested violation, so the district court struck it. 2 Appellate Case: 24-6243 Document: 35-1 Date Filed: 07/29/2025 Page: 3

Block’s supervised release period was turbulent but, despite setbacks, Block was

trying to remain sober and seek treatment. The probation officer recommended

another continuance to allow Block a second opportunity for treatment, this time at

the inpatient level. The district court expressed some reluctance but nevertheless

agreed to continue the hearing for 90 days so Block could attend inpatient treatment.

Block successfully completed inpatient treatment and requested a continuance

of the August 2024 hearing to secure stable housing, which the district court granted.

Around September 2024, however, Block again violated the terms of his supervised

release by using methamphetamine and marijuana (in addition to failing to report to

two random drug tests). For this violation, plus the earlier violations, the United

States Sentencing Guidelines suggested seven to 13 months in prison.

Probation recommended a 12-month sentence. The probation officer testified,

“we have extended every available effort and opportunity . . . over the course of

supervision; and despite all of the efforts and chances that have been given, we have

continued to see a diminished return on those efforts.” R. vol. 3, 48. Block argued

that his conduct while on supervised release did not warrant a 12-month sentence and

suggested a six-month sentence was more reasonable. The district court imposed a

sentence of 12 months and one day in prison and six months of supervised release.

Block appeals.

Analysis

In assessing whether there is any nonfrivolous basis for appeal, we begin with

the district court’s decision to revoke Block’s supervised release. A district court may

3 Appellate Case: 24-6243 Document: 35-1 Date Filed: 07/29/2025 Page: 4

“revoke a term of supervised release” if it “finds by a preponderance of the evidence

that the defendant violated a condition of supervised release.” 18 U.S.C.

§ 3583(e)(3); see also United States v. Jones, 818 F.3d 1091, 1097 (10th Cir. 2016)

(explaining that appellate courts review supervised-release revocations for abuse of

discretion). Here, Block stipulated to violating the terms of his supervised release. So

any challenge to the revocation itself would be frivolous.

We turn next to Block’s sentence. We typically review sentences for

procedural and substantive reasonableness. See United States v. Lucero, 747 F.3d

1242, 1246 (10th Cir. 2014). Block raised no procedural errors below, the Anders

brief suggests no such errors occurred, and we see nothing in the record indicating

otherwise. So any procedural challenge would be frivolous.

Substantive reasonableness “involves whether the length of the sentence is

reasonable given all the circumstances of the case in light of the factors set forth in

18 U.S.C. § 3553(a).” United States v. Alapizco-Valenzuela, 546 F.3d 1208, 1215

(10th Cir. 2008) (quoting United States v. Conlan, 500 F.3d 1167, 1169 (10th Cir.

2007)). We review the substantive reasonableness of sentences for abuse of

discretion. Id. at 1214. Under this deferential standard of review, we uphold a district

court’s decision unless it is “arbitrary, capricious, whimsical, or manifestly

unreasonable.” United States v. Munoz-Nava, 524 F.3d 1137, 1146 (10th Cir. 2008)

(quoting United States v. Byrne, 171 F.3d 1231, 1235–36 (10th Cir. 1999)). And we

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
United States v. Calderon
428 F.3d 928 (Tenth Circuit, 2005)
United States v. Conlan
500 F.3d 1167 (Tenth Circuit, 2007)
United States v. Munoz-Nava
524 F.3d 1137 (Tenth Circuit, 2008)
United States v. Alapizco-Valenzuela
546 F.3d 1208 (Tenth Circuit, 2008)
United States v. Timothy Byrne
171 F.3d 1231 (Tenth Circuit, 1999)
United States v. Lucero
747 F.3d 1242 (Tenth Circuit, 2014)
United States v. Jones
818 F.3d 1091 (Tenth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Block, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-block-ca10-2025.