United States v. Daniel Lockridge

140 F.4th 791
CourtCourt of Appeals for the Sixth Circuit
DecidedJune 18, 2025
Docket24-5784
StatusPublished

This text of 140 F.4th 791 (United States v. Daniel Lockridge) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Daniel Lockridge, 140 F.4th 791 (6th Cir. 2025).

Opinion

RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 25a0159p.06

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

┐ UNITED STATES OF AMERICA, │ Plaintiff-Appellee, │ > No. 24-5784 │ v. │ │ DANIEL LOCKRIDGE, │ Defendant-Appellant. │ ┘

Appeal from the United States District Court for the Eastern District of Tennessee at Chattanooga. No. 1:23-cr-00082-1—Curtis L. Collier, District Judge.

Argued: June 11, 2025

Decided and Filed: June 18, 2025

Before: SUTTON, Chief Judge; CLAY and THAPAR, Circuit Judges. _________________

COUNSEL

ARGUED: Howard W. Anderson, III, TRULUCK THOMASON LLC, Greenville, South Carolina, for Appellant. Brian Samuelson, UNITED STATES ATTORNEY’S OFFICE, Knoxville, Tennessee, for Appellee. ON BRIEF: Howard W. Anderson, III, TRULUCK THOMASON LLC, Greenville, South Carolina, for Appellant. Brian Samuelson, UNITED STATES ATTORNEY’S OFFICE, Knoxville, Tennessee, for Appellee. _________________

OPINION _________________

SUTTON, Chief Judge. Daniel Lockridge, who stands convicted of a methamphetamine- distribution charge, challenges two conditions of his supervised release, one requiring him to obtain mental-health treatment, the other requiring him to obtain substance-abuse treatment. No. 24-5784 United States v. Lockridge Page 2

He claims that both conditions flout the district court’s responsibilities under Article III of the U.S. Constitution because a probation officer oversees them. Seeing no constitutional infirmities, we affirm.

I.

Daniel Lockridge is a decorated combat Marine and a methamphetamine trafficker. After he returned to this country in 2009, he turned to methamphetamine—first to manage his post- traumatic stress disorder, then to make money. He soon became his supplier’s supplier, sourcing methamphetamine from Atlanta, Georgia, and reselling it to his supplier-turned-customer, among others, for distribution in Chattanooga, Tennessee. By the time law enforcement caught him, Lockridge had sold over seven kilograms of methamphetamine in the Volunteer State.

In 2024, Lockridge pleaded guilty to aiding and abetting possession with the intent to distribute methamphetamine. The district court sentenced Lockridge to 210 months in prison and three years of supervised release.

Two conditions of Lockridge’s supervised release require treatment for his mental-health and substance-abuse challenges. The first is a special condition that requires him to “participate in a program of mental health treatment, as directed by the probation officer, until such time as [he] is released from the program by the probation officer.” R.95 at 5. The second is a special condition that requires Lockridge to “participate in a program of testing and/or treatment for drug and/or alcohol abuse, as directed by the probation officer, until such time as [he] is released from the program by the probation officer.” R.95 at 5.

At sentencing, Lockridge objected that the district court must “preauthorize any inpatient treatment,” as opposed to outpatient treatment, under both conditions and “set a frequency for drug testing” under the second condition. R.104 at 6. The district court, Lockridge maintained, may not constitutionally delegate these decisions to the probation officer. The court overruled Lockridge’s objection. Lockridge appeals, contesting these features of his sentence. No. 24-5784 United States v. Lockridge Page 3

II.

Article III of the U.S. Constitution vests the judicial power in the federal courts, including the “[i]ndisputably” judicial power “to impose the punishment provided by law.” Ex parte United States, 242 U.S. 27, 41–42 (1916). The courts may not delegate the judicial power to the executive or legislative branches. See United States v. Nixon, 418 U.S. 683, 704 (1974).

Article III requires courts, consistent with congressional criminal statutes, to exercise any discretion in the imposition of a punishment. But it does not require courts alone to propose the initial conditions of a sentence. The district court may use the assistance of nonjudicial officers, as it does for other exercises of the judicial power, such as calculating damages, Thornton v. Carson, 11 U.S. (7 Cranch) 596, 600 (1813) (referee), analyzing common-law claims tied up in bankruptcy, Exec. Benefits Ins. Agency v. Arkison, 573 U.S. 25, 38 (2014) (bankruptcy judge), or proposing a report and recommendation for the disposition of a motion for summary judgment, Beard v. Banks, 548 U.S. 521, 528 (2006) (magistrate). What makes this assistance permissible is that the Article III court remains in charge. It reviews, then accepts, modifies, or rejects, the nonjudicial officers’ recommendations. See Kansas v. Nebraska, 574 U.S. 445, 453 (2015).

This type of collaboration between Article III courts and non–Article III officers is common in criminal sentencing. District courts regularly look to probation officers, who lack an Article III commission, to report on each defendant’s background, to propose a Guidelines sentencing range, and to make other recommendations about the conditions of a sentence. While the probation officers’ proposals benefit the court, they do not bind it. The judicial power to impose the punishment remains with, and remains a final decision by, the court. See generally United States v. Yopp, 453 F.3d 770, 772, 774 (6th Cir. 2006).

So it is with supervised release. District courts may work with probation officers to “craft[] and manage[]” the conditions of each defendant’s release, just as they do for other aspects of sentencing. United States v. Amin, 85 F.4th 727, 734 (4th Cir. 2023). But they must retain the “ultimate authority” to modify or enforce those conditions, just as they do for other exercises of the judicial power. United States v. Campbell, 122 F.4th 624, 634–35 (6th Cir. No. 24-5784 United States v. Lockridge Page 4

2024) (quotation omitted); United States v. Vaughn, 119 F.4th 1084, 1087–88 (6th Cir. 2024); see also Weinberger v. United States, 268 F.3d 346, 360 (6th Cir. 2001).

As is often the case with in-the-future conditions of supervised release, the district court in this instance did not spell out precisely how these conditions would be implemented years in the future. We construe that silence not as a sign of constitutional infirmity, but as a sign that the court, the parties, and the probation officer will work through the appropriate condition at the time it becomes relevant. See United States v. Shultz, 733 F.3d 616, 624 (6th Cir. 2013). Put another way, when we could read an open-textured condition to violate Article III by placing ultimate authority in the probation officer, or to respect Article III by retaining that authority for the court, we adopt the reading that avoids, not exacerbates, a potential constitutional problem. See id.; United States v. Ossa-Gallegos, 491 F.3d 537, 543 (6th Cir. 2007) (en banc); see also United States v. Mike, 632 F.3d 686, 696 (10th Cir. 2011).

These principles frame our fresh review of Lockridge’s two challenges to the conditions of his supervised release.

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Related

Thornton v. Carson
11 U.S. 596 (Supreme Court, 1813)
Ex Parte United States
242 U.S. 27 (Supreme Court, 1916)
United States v. Nixon
418 U.S. 683 (Supreme Court, 1974)
Beard v. Banks
548 U.S. 521 (Supreme Court, 2006)
United States v. Mike
632 F.3d 686 (Tenth Circuit, 2011)
United States v. Timothy Lantz
443 F. App'x 135 (Sixth Circuit, 2011)
Barrett N. Weinberger v. United States
268 F.3d 346 (Sixth Circuit, 2001)
United States v. Stephen A. Balon
384 F.3d 38 (Second Circuit, 2004)
United States v. Gregory Yopp
453 F.3d 770 (Sixth Circuit, 2006)
United States v. Carlos Alberto Ossa-Gallegos
491 F.3d 537 (Sixth Circuit, 2007)
United States v. Solomon Carpenter
702 F.3d 882 (Sixth Circuit, 2012)
United States v. Robert Shultz
733 F.3d 616 (Sixth Circuit, 2013)
United States v. Lee
502 F.3d 447 (Sixth Circuit, 2007)
United States v. Rhodes
552 F.3d 624 (Seventh Circuit, 2009)
United States v. Esparza
552 F.3d 1088 (Ninth Circuit, 2009)
United States v. Bennett
823 F.3d 1316 (Tenth Circuit, 2016)
United States v. Martinez
987 F.3d 432 (Fifth Circuit, 2021)
United States v. Matta
777 F.3d 116 (Second Circuit, 2015)
United States v. Ali Amin
85 F.4th 727 (Fourth Circuit, 2023)

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Bluebook (online)
140 F.4th 791, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-daniel-lockridge-ca6-2025.