United States v. Jonathon Patterson

• Court: Court of Appeals for the Fourth Circuit
• Decided: September 30, 2025
• Docket: 25-6220
• Status: Unpublished

Opinion

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UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-6220

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JONATHON TERRELL PATTERSON, a/k/a Joe-Joe,

Defendant – Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Statesville. Kenneth D. Bell, District Judge. (5:06-cr-00022-KDB-SCR-12)

Submitted: September 25, 2025 Decided: September 30, 2025

Before GREGORY and WYNN, Circuit Judges, and FLOYD, Senior Circuit Judge.

Vacated and remanded by unpublished per curiam opinion.

Jonathon Terrell Patterson, Appellant Pro Se.

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PER CURIAM:

Jonathan Tarrell Patterson appeals the district court’s order denying his motion for

early termination of his supervised release. In his motion, Patterson argued that this relief

was appropriate because he had successfully completed 45 months of supervised release,

had complied with all his conditions of release, and passed all his drug tests. Patterson’s

supervising officer opposed early termination, highlighting that Patterson still needed help

obtaining a job, a driver’s license, and custody of his granddaughter. Agreeing with

Patterson’s supervising officer, the court noted that Patterson was unemployed, without a

license, and in the process of seeking full custody of his granddaughter. The district court

thus denied Patterson’s motion.

We “review a district court’s decision whether to terminate an individual’s term of

supervised release before the expiration of the term under 18 U.S.C. § 3583(e) under the

narrow abuse of discretion standard.” United States v. Pregent, 190 F.3d 279, 282 (4th Cir.

1999). “A district court abuses its discretion when it acts arbitrarily or irrationally, fails to

consider judicially recognized factors constraining its exercise of discretion, relies on

erroneous factual or legal premises, or commits an error of law.” United States v. Dillard,

891 F.3d 151, 158 (4th Cir. 2018) (internal quotation marks omitted).

Pursuant to 18 U.S.C. § 3583(e)(1), after a defendant has served one year of

supervised release, a district court may terminate the remaining term after considering

certain 18 U.S.C. § 3553(a) factors, if the court “is satisfied that such action is warranted

by the conduct of the defendant released and the interest of justice.” 18 U.S.C. § 3583(e)(1).

The § 3553(a) factors that the district court must consider are: (1) the nature and

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circumstances of the offense and the history and characteristics of the defendant; (2) the

need for the sentence imposed to afford adequate deterrence to criminal conduct; (3) the

need for the sentence imposed to protect the public from further crimes of the defendant;

(4) the need for the sentence imposed to provide the defendant with needed educational or

vocational training, medical care, or other correctional treatment in the most effective

manner; (5) the kinds of sentence and sentencing range established for the applicable

category of offense committed, as set forth in the Sentencing Guidelines; (6) pertinent

policy statements issued by the Sentencing Commission; (7) the need to avoid unwarranted

sentence disparities among defendants with similar records who have been found guilty of

similar conduct; and (8) the need to provide restitution to any victims of the offense. 18

U.S.C. §§ 3583(e), 3553(a)(1), (a)(2)(B)-(D), (a)(4)-(7).

Here, the record does not indicate whether the district court considered the relevant

statutory factors. Accordingly, we are unable to meaningfully review this portion of the

district court’s order. We therefore vacate the district court’s order denying Patterson’s

§ 3583(e) motion and remand for further proceedings. See United States v. Sheppard, 17

F.4th 449, 456 (3d Cir. 2021) (recognizing that, while district courts have much discretion

in deciding an early termination motion and can satisfy the statute by “includ[ing] a

statement that it considered the § 3553(a) factors in its analysis,” it is not permissible for a

court to deny such a motion “without any indication in its order that it applied the proper

legal standard”). We express no view on the merits of Patterson’s motion for early

termination of supervised release. We dispense with oral argument because the facts and

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legal contentions are adequately presented in the materials before this court and argument

would not aid the decisional process.

VACATED AND REMANDED