United States v. Fuller

CourtDistrict Court, District of Columbia
DecidedAugust 1, 2025
DocketCriminal No. 2018-0054
StatusPublished

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

Bluebook
United States v. Fuller, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. No. 18-cr-54-ACR-MAU JEROME FULLER,

Defendant.

REPORT AND RECOMMENDATION

On July 10, 2024, the District Court referred this matter to this Court to conduct a hearing

and prepare a report and recommendation regarding Defendant Jerome Fuller’s (“Mr. Fuller”)

alleged supervised release violations. See Min. Order (July 10, 2024). 1 In petitions dated July 8,

2024 (“Original Petition”) and April 28, 2025 (“Updated Petition”), the United States Office of

Probation (“Probation”) alleged that Mr. Fuller violated five of his conditions of supervised

release. The Court held a substantive hearing on July 10, 2025. Min. Entry (July 10, 2025). Upon

consideration of the Parties’ positions and the relevant sentencing factors, this Court: 1) finds that

Mr. Fuller has violated one of the terms of his supervised release by using controlled substances on

May 3, 2023, July 15, 2023, March 12, 2024, and December 16, 2024; 2) recommends that the

District Court deny the requests of the Government and Probation to sentence Mr. Fuller to an

additional term of incarceration; and 3) further recommends that the District Court order that Mr.

Fuller continue his supervised release until his term expires on October 12, 2025.

1 Under Local Criminal Rule 32.1(e), a district judge may delegate a hearing on an alleged violation to a magistrate judge. See LCrR 32.1(e). The magistrate judge “shall file written findings and recommendations” and the district judge shall make a “de novo determination of those portions of the magistrate judge’s report to which objections are made and may accept, reject, or modify in whole or in part, the findings and recommendations made by the magistrate judge.” Id. The district judge may rule based on the record developed before the magistrate judge or consider additional evidence. See id.

1 BACKGROUND

I. Initial Sentencing and Alleged Supervised Release Violations

On May 22, 2018, Mr. Fuller pleaded guilty to distribution of phencyclidine in violation of

21 U.S.C. §§ 841(a)(1), (b)(1)(C). ECF No. 12. On August 16, 2018, the District Court sentenced

him to sixty-three months of imprisonment and three years of supervised release. ECF No. 20.

His term of supervised release began on October 13, 2022 and is set to expire on October 12, 2025.

ECF No. 38 at 1. 2

On July 8, 2024, Probation filed the Original Petition, in which it alleged five violations.

ECF No. 38. According to Probation, Mr. Fuller had:

• Failed to report to his supervising officer as instructed;

• Used controlled substances (Fentanyl, Norfentanyl, and Cannaboids);

• Failed to submit to substance abuse testing;

• Possessed controlled substances (Fentanyl, Norfentanyl, and Cannaboids); and

• Failed to comply with mandated substance abuse treatment.

Id.

On September 5, 2024, Mr. Fuller appeared for an initial hearing on the Original Petition.

Min. Entry (Sep. 5, 2024); see also ECF No. 40. At that hearing, the Parties agreed that Mr. Fuller

should be evaluated for potential inpatient substance abuse treatment. ECF No. 40. The next day,

Mr. Fuller completed an intake interview with the treatment facility Samaritan Inns. Id. The

facility agreed to accept Mr. Fuller for a twenty-eight-day inpatient program. Id. The Court

ordered Mr. Fuller released to Samaritan Inns for purposes of attending the program. Min. Entry

(Sep. 9, 2024); ECF No. 40.

2 Citations are to the page numbers in the ECF headers.

2 II. Mr. Fuller’s Progress on Release

Most of Probation’s allegations stemmed from Mr. Fuller’s substance use disorder. Before

scheduling a substantive revocation hearing and in light of the fact that there were no allegations

that Mr. Fuller committed any new crimes on release, the Court found it appropriate to give Mr.

Fuller the opportunity to seek treatment. Thus, with the Parties largely in agreement, the Court

deferred the substantive hearing and monitored Mr. Fuller’s progress through a series of status

conferences.

On September 30, 2024, the Parties reported that Mr. Fuller left Samarian Inns early. ECF

No. 43 ¶ 2. After leaving the program, Mr. Fuller enrolled in a detox program at the Psychiatric

Institute of Washington. Id. He then transferred to Federal City Recovery Services (“Federal

City”) to begin another twenty-eight-day treatment program. Id.

At a status conference on October 28, 2024, the Parties reported that Mr. Fuller had

completed the Federal City program. See Min. Entry (Oct. 28, 2024). Further, Mr. Fuller intended

to enroll in an outpatient program, which would also help him find employment. Defense counsel

and Probation disagreed on where Mr. Fuller was living. Defense counsel stated that Mr. Fuller

was living with his aunt, whereas Probation stated that its records reflected a different address.

The Court ordered the Parties to attempt to resolve the residence issue together and to return for a

status conference in December.

At the December 2024 status conference, Probation reported three issues with Mr. Fuller’s

compliance. See Min. Entry (Dec. 17, 2024). First, Mr. Fuller tested positive for fentanyl on one

occasion. Second, Mr. Fuller failed to enroll in an outpatient treatment program. Third, Probation

still could not verify Mr. Fuller’s residence. Upon hearing from all Parties, the Court concluded

that some of these problems arose because defense counsel, Probation, and Mr. Fuller had failed

to communicate with each other. The Court ordered the Parties to file a status report in two weeks

3 with an update on Mr. Fuller’s residence and enrollment in an outpatient program. See Min. Order

(Dec. 17, 2024). The Court also ordered the Parties to appear for another status conference in early

February. See id.

On December 30, 2024, the Parties jointly reported that they had resolved the issues with

Mr. Fuller’s residence. ECF No. 47 ¶ 2. The Parties further reported that Probation directed Mr.

Fuller to appear at a later date for assessment for potential outpatient treatment. Id. ¶ 3.

At the status conference on February 3, 2025, the Parties advised that some but not all

issues had been resolved. See Min. Entry (Feb. 3, 2025). On the one hand, Mr. Fuller had enrolled

in an outpatient treatment program and was in stable housing. On the other hand, Probation had

been unable to obtain another drug test since December 2024. Defense counsel represented that

Mr. Fuller had provided drug tests to his work training program. The Court reminded Mr. Fuller

that, even if true, he was required to report specifically to Probation for drug testing.

On February 7, the Parties jointly reported that Mr. Fuller provided Probation with a

negative drug test. ECF No. 48 ¶ 2. On February 24, however, the Parties reported that Mr. Fuller

missed a drug test on February 18. ECF No. 49 ¶ 3. Mr. Fuller claimed that his phone had been

stolen and that he did not receive Probation’s text message. Id. In a subsequent report, Probation

explained that it visited Mr. Fuller at his job site on March 4, but Mr. Fuller could not provide a

sample. ECF No. 50 at 1. Although Probation then directed Mr. Fuller to be tested at the Probation

office on both March 4 and March 6, Mr. Fuller failed to appear on either date. Id. at 1–2.

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