United States v. LeSean Roberts

• Court: Court of Appeals for the Sixth Circuit
• Decided: April 2, 2026
• Docket: 25-3789
• Status: Unpublished

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0155n.06

Case No. 25-3789 FILED UNITED STATES COURT OF APPEALS Apr 02, 2026 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE NORTHERN ) DISTRICT OF OHIO LESEAN ROBERTS, ) Defendant-Appellant. ) ) OPINION

Before: CLAY, McKEAGUE, and NALBANDIAN, Circuit Judges.

McKEAGUE, Circuit Judge. LeSean Roberts moved to terminate his supervised release.

Because the record does not make clear that the district court considered the relevant 18 U.S.C.

§ 3553(a) factors in denying Roberts’s motion, we VACATE the district court’s order and

REMAND.

I.

Nearly two decades ago, LeSean Roberts was convicted of drug offenses. At the time,

based on Roberts’s criminal history, the district court was required to impose a mandatory term of

life imprisonment. But in 2016, the President commuted Roberts’s sentence to 240 months. And

then, after Roberts had served 180 months’ imprisonment, the district court reduced his custodial

sentence to time served and imposed an eight-year period of supervised release.

Since his release, Roberts has twice moved to end his supervision. The district court denied

his first motion, which came just a year-and-a-half after his release. So, Roberts renewed his No. 25-3789, United States v. Roberts

request when his supervision term neared its halfway point. But the district court denied that

request too.

A pair of docket entries memorialize the district court’s more recent ruling. The first is a

marginal entry on Roberts’s motion, with an “x” to indicate that the request was denied. The

second consists of a supervision report prepared by the probation office, detailing Roberts’s

compliance with supervision, and reciting the relevant 18 U.S.C. § 3553(a) factors. Looking to

Roberts’s history and characteristics, the report recommended denying Roberts’s motion because

“he is a career offender.” R. 243, PageID 2096. The district court refiled the supervision report in

its entirety and checked a box on the last page indicating that Roberts’s request was denied.

Roberts appealed, arguing that the district court abused its discretion in denying his motion.

The government agrees.

II.

A district court may “terminate a term of supervised release and discharge the defendant

released at any time after the expiration of one year of supervised release . . . if it 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). But, in exercising that discretion, “the record must demonstrate that the

district court considered the relevant § 3553(a) factors before denying an early termination

motion.” United States v. Tavarez, 141 F.4th 750, 758 (6th Cir. 2025); see 18 U.S.C. § 3583(e).

That’s because a district court “abuses its discretion in denying a motion for sentence reduction

when the record as a whole fails to satisfy us that the district court considered the parties’

arguments and had a reasoned basis for exercising its own legal decisionmaking authority.”

Tavarez, 141 F.4th at 757 (citation modified).

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Against that backdrop, Tavarez makes clear that a district court cannot deny a defendant’s

motion for early termination of his supervised release with only a checkmark. Id. at 758. Here,

across two orders, the district court denied Roberts’s motion by marking an “x” on a line. In doing

so, it did not mention § 3553(a) or offer any measure of additional reasoning. Put differently,

the district court provided “no indication” that it considered the relevant sentencing factors. Id.

at 759. The government concedes as much. See Appellee’s Br. at 6. And we have consistently

deemed similar orders insufficient. See, e.g., Tavarez, 141 F.4th at 759; United States v. Morgan,

No. 25-3714, 2026 WL 249619, at *1 (6th Cir. Jan. 27, 2026); United States v. Flowers, No.

25-3523, 2025 WL 3525260, at *1 (6th Cir. Dec. 4, 2025); United States v. Evans, No. 25-5118,

2025 WL 2486607, at *1-2 (6th Cir. Aug. 26, 2025).

True, the supervision report includes a recitation of the § 3553(a) factors. Cf. Tavarez, 141

F.4th at 758 (recognizing that when there was “no mention of the factors anywhere” in a

supervision report, a similar order did “not show that the district court reasoned through Tavarez’s

arguments or considered the relevant § 3553(a) factors”). Even still, the district court’s orders

contain no language indicating it considered the relevant sentencing factors. See Morgan, 2026

WL 249619, at *1 (Bush, J., concurring). Nor do the orders “explicitly” adopt the supervision

report’s analysis. Id. While we have recognized (in other contexts) that a barebones order may

sometimes be sufficient, there must be at least some indication in the record as to how the district

court considered the § 3553(a) factors. See, e.g., United States v. Davis-Malone, 128 F.4th 829,

834 (6th Cir.) (citing Chavez-Meza v. United States, 585 U.S. 109, 113 (2018)), cert. denied, 145

S. Ct. 2827 (2025). There is nothing of the sort here. Without more, the district court’s checkmark

denial does not allow us to “discern from the record how or why denying the motion to terminate

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comported with consideration of the relevant § 3553(a) factors.” Tavarez, 141 F.4th at 758–59

(citation modified).

The district court’s omission of any analysis leads to other problems as well. In reciting

the § 3553(a) factors, the supervision report referred to Roberts as a career offender. But, as

Roberts points out, the district court previously concluded that he was improperly classified as a

career offender at sentencing (although, at the time, that error had no impact, given the statutory

minimum term). See United States v. Montanez, 442 F.3d 485, 494 (6th Cir. 2006). Because of

the district court’s lack of analysis, we cannot say how, or even if, that erroneous offender

classification factored into the decision to deny Roberts’s motion.

III.

All told, we VACATE the district court’s order denying Roberts’s motion to terminate his

supervised release and REMAND consistent with Tavarez.

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