United States v. Laphonse Young

• Court: Court of Appeals for the Eleventh Circuit
• Decided: April 29, 2026
• Docket: 25-11678
• Status: Unpublished

Opinion

USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 1 of 10

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11678 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

LAPHONSE YOUNG, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Alabama D.C. Docket No. 1:09-cr-00029-JB-B-1 ____________________

Before LUCK, LAGOA, and BLACK, Circuit Judges. PER CURIAM: Laphonse Young appeals the district court’s revocation of his term of supervised release. Young argues that (1) the district court lacked jurisdiction under 18 U.S.C. § 3583(i) to revoke his USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 2 of 10

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term of supervised release after it expired; (2) the district court abused its discretion by admitting hearsay evidence during the rev- ocation hearing; and (3) the district court erred by failing to provide Young the opportunity to object to a model-search condition for his new term of supervised release. After review, 1 we affirm. I. DISCUSSION A. Jurisdiction “A term of supervised release ends on its date of expiration.” United States v. Murat, 132 F.4th 1347, 1350 (11th Cir. 2025). A dis- trict court lacks jurisdiction to revoke a defendant’s term of super- vised release once it expires except under certain statutory excep- tions. See United States v. Okoko, 365 F.3d 962, 964 (11th Cir. 2004). Recently, the Supreme Court reviewed a circuit split on the issue of whether district courts can revoke a defendant’s term of supervised release after it expires based on actions taken after the expiration solely because the defendant absconded while under su- pervision. Rico v. United States, No. 24-1056, 607 U.S. ---, manuscript op. at *3-4 (U.S. Mar. 25, 2026). The Supreme Court held that dis- trict courts cannot revoke a defendant’s term of supervised release

1 “We review questions concerning a district court’s subject matter jurisdic-

tion de novo.” United States v. Murat, 132 F.4th 1347, 1349 (11th Cir. 2025). We review a revocation of supervised release and evidentiary issues for abuse of discretion. United States v. Frazier, 26 F.3d 110, 112 (11th Cir. 1994); United States v. Novaton, 271 F.3d 968, 1005 (11th Cir. 2001). “We review de novo whether a district court has given a defendant the required opportunity to ob- ject to its factual and legal findings.” United States v. Mosely, 31 F.4th 1332, 1334 (11th Cir. 2022). USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 3 of 10

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in that way because there was no statutory basis for extending a defendant’s term of supervised release based on abscondment. Id. at *4-12. In reaching its decision, the Supreme Court contrasted the judge-made abscondment rule with statutory provisions that expressly allow district courts to extend a defendant’s term of su- pervised release and to retain authority to revoke a defendant’s term of supervised release after expiration. Id. at *5-6. One of the statutory provisions the Court cited was § 3583(i), which was not at issue in the case before it. Id. at *6. Unlike in Rico, in this case the district court’s jurisdiction to revoke Young’s term of supervised release after it expired was based on an explicit statutory provision—§ 3583(i). Section 3583(i) states, The power of the court to revoke a term of super- vised release for violation of a condition of supervised release . . . extends beyond the expiration of the term of supervised release for any period reasonably neces- sary for the adjudication of matters arising before its expiration if, before its expiration, a warrant or sum- mons has been issued on the basis of an allegation of such a violation. 18 U.S.C. § 3583(i). Thus, to revoke a defendant’s term of super- vised release under § 3583(i) after the term expired, (1) the revoca- tion must be based on actions that the defendant took during the term of supervised release, (2) the district court must have issued a warrant or summons “on the basis of” those actions during the USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 4 of 10

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term of supervised release, and (3) the delayed exercise of jurisdic- tion must be “reasonably necessary.” It is undisputed that the district court revoked Young’s term of supervised release based on actions that he took while he was still on supervised release. It is also undisputed that the district court issued an arrest warrant on the basis of those actions before Young’s term of supervised release expired. Young only argues on appeal that the district court lacked jurisdiction under § 3583(i) because (1) the clerk of court signed the arrest warrant, but the district court judge’s signature was required for the warrant to be effective under Fed. R. Crim. P. 4(b), and (2) the government failed to establish that the district court’s de- layed exercise of jurisdiction under § 3583(i) was “reasonably nec- essary.” Young is wrong on both counts. First, Young is incorrect that the district court judge needed to sign the arrest warrant. In United States v. Moore, we held that Rule 4’s signature requirement does not apply to summonses for purposes of § 3583(i). 443 F.3d 790, 794 n.4 (11th Cir. 2006) (citing United States v. Bernardine, 237 F.3d 1279, 1281 n.1 (11th Cir. 2001)). In that case, like in this one, the clerk of court, not the district court judge, signed a summons that was used to trigger the district court’s jurisdiction under § 3583(i). Id. at 792-93. The defendant primarily argued that the summons did not satisfy § 3583(i) because it was not issued until after the defendant’s term of supervised re- lease expired. Id. at 794. We rejected that argument in the body of the opinion. Id. USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 5 of 10

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We additionally stated in a footnote that the defendant ar- gued, “the summons does not meet the signature requirement un- der Fed. R. Crim. P. 4(b).” Id. at 794 n.4. We rejected that argu- ment because it concluded that “Rule 4 does not apply to the pre- sent case.” Id. We cited United States v. Bernardine, which stated, “Rule 4 pertains to summons upon complaint and Rule 9 pertains to summons upon indictment or information . . . . No other rule of criminal procedure, relevant statute or case law supports the appli- cation of Rules 4 or 9 in the context of a supervised release violation hearing where the court already has supervisory jurisdiction and authority over the defendant.” Bernardine, 237 F.3d at 1281 n.1 (ci- tations omitted). Moore’s signature holding resolves this case. In Moore, we explicitly held—rejecting an argument that is almost identical to Young’s in this case—that Rule 4(b)’s signature requirement did not apply when the district court was exercising jurisdiction under § 3583(i). Moore, 443 F.3d at 794 n.4. Section 3583(i) does not dis- tinguish between summonses and arrest warrants, so Moore’s hold- ing applies equally here. See 18 U.S.C. § 3583(i) (permitting exercise of jurisdiction when “a warrant or summons has been issued”). Therefore, the arrest warrant issued in this case was sufficient to trigger the district court’s jurisdiction under § 3583(i) even though it was only signed by the clerk of court at the direction of the court. See also United States v. Hondras, 296 F.3d 601, 602-03 (7th Cir. 2002) (holding that district court judge did not need to sign arrest warrant for it to trigger jurisdiction under § 3583(i)); United States v. Vallee, 677 F.3d 1263, 1265-66 (9th Cir. 2012) (agreeing with Hondras). USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 6 of 10

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Second, Young is incorrect that the government failed to es- tablish that an extension under § 3583(i) was “reasonably neces- sary.” The reason for the delay between the issuance of the war- rant and the revocation of supervised release was that law enforce- ment could not find Young. As Probation Officer Stan McGilvray testified at the revocation hearing, when law enforcement went to Young’s address of record to arrest him, they were told he no longer lived there. And when law enforcement eventually located Young, he was living in Texas. An extension under § 3583(i) was “reasonably necessary” because Young’s own actions prevented the district court from revoking his supervised release. See United States v. Villarreal, 613 F.3d 1344, 1351 (11th Cir. 2010) (stating in reviewing a speedy-trial claim that “the defendant’s own evasive tactics constitutes a valid reason for delay”); see also United States v. Morales-Isabarras, 745 F.3d 398, 401 (9th Cir. 2014) (“Courts have generally taken a practical approach to the determination of what delays are ‘reasonably necessary’ for purposes of § 3583(i).”). Additionally, although the delay between the issuance of the arrest warrant and the revocation was approximately two years, the delay between the expiration of Young’s term of supervised re- lease and the revocation was only a few months. For the above reasons, the district court had jurisdiction to revoke Young’s term of supervised under § 3583(i). B. Hearsay Evidence “[T]he Federal Rules of Evidence do not apply in supervised release revocation proceedings.” United States v. Frazier, 26 F.3d USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 7 of 10

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110, 114 (11th Cir. 1994). However, “the admissibility of hearsay [during revocation hearings] is not automatic.” Id. That is because “[d]efendants involved in revocation proceedings are entitled to certain minimal due process requirements,” including “the right to confront and cross-examine adverse witnesses.” Id. (citing Morris- sey v. Brewer, 408 U.S. 471, 489 (1972)). “Thus, in deciding whether or not to admit hearsay testimony, the court must balance the de- fendant’s right to confront adverse witnesses against the grounds asserted by the government for denying confrontation” and must ensure that the offered hearsay is “reliable.” Id. In this case, the district court did not explicitly balance the parties’ interests or make an express finding as to the reliability of the challenged hearsay documents. Yet, even if this constituted er- ror under Frazier, vacatur would not be warranted because Young failed to show that any such error was prejudicial. The admission of hearsay evidence during a revocation hearing does not violate due process “as long as [the evidence] bears some indicia of reliability.” United States v. Taylor, 931 F.2d 842, 847 (11th Cir. 1991). 2 Therefore, to successfully establish re- versible error based on the admission of hearsay evidence at a rev- ocation hearing, a defendant “must show (1) that the challenged

2 Taylor was decided under the federal probation system that was in place prior

to the implementation of the federal supervised-release system. See 931 F.2d at 844-47. Nevertheless, Taylor is applicable because there is “no significant conceptual difference between the revocation of probation or parole and the revocation of supervised release.” Frazier, 26 F.3d at 113-14. USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 8 of 10

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evidence is materially false or unreliable, and (2) that it actually served as the basis for the sentence.” Id. (quotation marks omit- ted); see also United States v. Baptiste, 935 F.3d 1304, 1315-17 (11th Cir. 2019) (explaining in the sentencing context that a district court can rely on hearsay evidence without expressly finding that it is re- liable if the evidence bears “traditional indicia of reliability”). Young has failed to satisfy this burden as to the hearsay doc- uments relating to his new-offense violation. Young does not point to any valid ground indicating that the relevant financial docu- ments and bank statements were “materially false or unreliable.” See Taylor, 931 F.2d at 847. Rather, the documents bear indicia of reliability, such as Young’s identifying information. The specific amounts of some of the allegedly fraudulent transactions also lined up exactly with multiple deposit amounts shown on Young’s bank statements. Moreover, the government submitted an affidavit from Discover’s custodian of records attesting to the authenticity of the Discover statement, and Detective Kent Castillo testified that he spoke with an employee of the business victim about the business’s documents. Young also did not provide any reasons to the district court why the documents were materially false or unreliable. Rather, Young argued that the documents did not establish whether he himself conducted the relevant transactions or if he was a victim of identity theft. That argument goes to the district court’s weighing of the evidence rather than the reliability of the documents. USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 9 of 10

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Because Young has failed to establish that the financial doc- uments were materially false or unreliable, he has failed to establish that the district court reversibly abused its discretion by relying on those documents to revoke his supervised release based on the new-offense violation. Young does not challenge the merits of the district court’s revocation based on that violation, and so Young has not shown that the district court abused its discretion on this ground. As a result, we need not consider Young’s arguments re- garding the other alleged violations. See United States v. Vandergrift, 754 F.3d 1303, 1307 (11th Cir. 2014) (“[W]here the district court’s decision to revoke a defendant’s supervised release is supported ad- equately by one alleged violation, a possible error in consideration of other allegations is harmless.”). C. Opportunity to Object “[A]fter imposing a sentence, the district court must give the parties an opportunity to object to the court’s ultimate findings of fact, conclusions of law, and the manner in which the sentence is pronounced, and must elicit a full articulation of the grounds upon which any objection is based.” United States v. Campbell, 473 F.3d 1345, 1347 (11th Cir. 2007) (citing United States v. Jones, 899 F.2d 1097, 1102 (11th Cir. 1990), overruled on other grounds by United States v. Morrill, 984 F.2d 1136 (11th Cir. 1993)). This rule applies to su- pervised-release revocation proceedings. Id. at 1348. The district court did not fail to adequately elicit objections during the revocation hearing with respect to the model-search USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 10 of 10

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condition. After announcing its sentence, the district court ex- plained that it would impose the model-search condition if that condition had not been previously imposed. The court then asked Young’s counsel, “any objections or any matters that you need to put on the record at this time?” Young’s counsel replied, “I stand on all of my previous objections, Your Honor. So I don’t think I have any further ones at this time.” The district court’s elicitation was sufficient to provide Young with the opportunity to object to the model-search condi- tion. It does not matter that the district court only officially im- posed the condition subsequently once it confirmed that the con- dition had not previously been imposed. That is because the court had already stated its intention to impose the condition and pro- vided Young with the opportunity to object to it. Therefore, the district court did not err. II. CONCLUSION The district court had jurisdiction to revoke Young’s term of supervised release under § 3583(i). The district court did not re- versibly abuse its discretion by relying on hearsay evidence during the revocation hearing. And the district court did not err by failing to adequately elicit objections. Accordingly, we affirm the district court’s revocation of supervised release. AFFIRMED.