United States v. Joseph Jones

CourtCourt of Appeals for the Eleventh Circuit
DecidedJanuary 12, 2026
Docket25-12918
StatusUnpublished

This text of United States v. Joseph Jones (United States v. Joseph Jones) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh 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. Joseph Jones, (11th Cir. 2026).

Opinion

USCA11 Case: 25-12918 Document: 22-1 Date Filed: 01/12/2026 Page: 1 of 17

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12918 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

JOSEPH JONES, a.k.a. Jamonte Brown, a.k.a. Alton Jamonte Brown, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:14-cr-00001-SDG-1 ____________________

Before JORDAN, ABUDU, and KIDD, Circuit Judges. PER CURIAM: USCA11 Case: 25-12918 Document: 22-1 Date Filed: 01/12/2026 Page: 2 of 17

2 Opinion of the Court 25-12918

Joseph Jones appeals his seven-month revocation sentence imposed for violations of his supervised release. On appeal, Jones argues that his sentence is procedurally and substantively unrea- sonable. After careful review of the record, we find no reversible error, so we affirm. I. FACTUAL BACKGROUND & PROCEDURAL HISTORY In 2014, Jones was charged by information of knowingly possessing stolen firearms in violation of 18 U.S.C. §§ 922(j) & 924(a)(2). He entered into a plea agreement with the govern- ment and pled guilty that same year, and was sentenced to 120 months’ imprisonment, to be followed by three years of super- vised release. The district court’s judgment provided several terms which Jones would be subject to while he was on supervised re- lease. One of these conditions provided that Jones was to “refrain from any unlawful use of a controlled substance” and would have to submit to periodic drug tests at the behest of a probation officer. Another condition required Jones to report in person to the proba- tion office and submit written reports to the probation officer each month. Jones would also have to participate, as directed by the probation officer, in a program for narcotic addition or drug or al- cohol dependency treatment. Jones completed his term of incarceration on April 29, 2022, and began serving his three-year term of supervised release. On November 17, a probation officer filed a violation report with the district court, alleging that Jones had violated several conditions of supervised release. The report alleged that Jones had used or USCA11 Case: 25-12918 Document: 22-1 Date Filed: 01/12/2026 Page: 3 of 17

25-12918 Opinion of the Court 3

possessed marijuana, methamphetamine, and amphetamines; and had failed to: submit to substance abuse testing, report to the pro- bation officer, and participate in drug treatment. At a revocation hearing, Jones admitted to the alleged violations in the report. In 2024, the district court revoked his supervised release and sen- tenced him to six months’ imprisonment followed by a one-year term of supervised release. The district court added a condition to Jones’s supervised release which would require him to participate in mental health treatment. After Jones served the custodial portion of his revocation sentence and was placed on supervised release a second time, a pro- bation officer filed a violation report in March 2025, alleging that Jones had violated a condition of his supervised release. The sec- ond report alleged that Jones had used or possessed marijuana and explained that, on five occasions, Jones had tested positive for it. The report explained that Jones had been released from prison on June 13, 2024, and had reported to the Atlanta Probation on June 17. On that day, Jones tested “presumably positive for THC” and Jones explained that he had smoked marijuana while incarcerated. The district court had held that violation in abeyance to allow for Jones to enroll in mental health treatment. Then, on August 13, Jones again tested “presumably positive for THC” and explained that he had smoked marijuana while celebrating his birthday. The court again held that violation in abeyance while Jones attended his regular mental health counseling services. The report also stated that, in January 2025, the probation officer told USCA11 Case: 25-12918 Document: 22-1 Date Filed: 01/12/2026 Page: 4 of 17

4 Opinion of the Court 25-12918

the court that Jones had tested positive for THC on two more oc- casions in October and December 2024. The court again held those violations in abeyance in January 2025. Finally, days after the court held the October and January reports in abeyance, Jones tested pre- sumably positive for THC for the fifth time. The court then re- quired Jones to appear for a revocation hearing. At a second revocation hearing, in April 2025, Jones admit- ted to the violations in the report: that he had tested positive for marijuana use five times. The court noted that the statutory max- imum for this violation, if it chose to revoke his supervised release, was two years. See 18 U.S.C. § 3583(e)(3). The court also calcu- lated a guideline range of 6–12 months’ imprisonment. Neither Jones nor the government objected to the calculation. The government recommended a seven-month sentence, which was the same as the probation officer’s recommendation, in large part because Jones’s first revocation for a near-identical viola- tion resulted in a six-month incarceration. It noted, however, that it made this recommendation reluctantly, as Jones had largely been compliant with the terms of his supervised release, except for the marijuana use violations. It also explained that additional super- vised release would not be beneficial because Jones was not a dan- ger to the public and had no other issues besides marijuana use. The court expressed frustration that Jones had spent six months in prison for previously violating the same conditions— drug use—and that he tested positive the day he left prison, signi- fying that he was using marijuana even while incarcerated for the USCA11 Case: 25-12918 Document: 22-1 Date Filed: 01/12/2026 Page: 5 of 17

25-12918 Opinion of the Court 5

same conduct. The government reiterated that, despite its recom- mendation, it believed Jones had been generally “doing well” and was not a danger to the public. Jones, through his attorney, recognized the court’s “frustra- tion” and explained that he was struggling with addiction. He also emphasized that he had obtained employment and had no contact with law enforcement outside of this case. He stressed that putting him back in jail would be counterproductive to his efforts at reha- bilitation and at staying employed. He therefore asked for a “non- custodial sentence” to allow for him to pursue a drug treatment program. The court agreed with Jones that additional incarcera- tion would be counterproductive, and it noted that it did not see any utility in using prison to address Jones’s substance abuse prob- lem. Accordingly, the court held sentencing for the violation in abeyance so long as Jones pursued drug treatment options with probation as his “number one priority.” 1 The court warned Jones, however, that if he failed “to go to treatment and take that treat- ment seriously” he would “get locked up.” After two intervening hearings where the court checked in on Jones’s treatment progress, the court held a final revocation hearing. At that hearing, the probation officer told the court that Jones had not “followed through” with his drug treatment plan.

1 The court explained that, if Jones was not going to “get treatment,” it could

“render a sentence today” that would involve a term of incarceration and no supervised release to follow. Jones stated that he wanted treatment instead, so the district court held the case in abeyance.

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United States v. Joseph Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joseph-jones-ca11-2026.