United States v. Sletten

CourtCourt of Appeals for the Tenth Circuit
DecidedJune 2, 2026
Docket25-1267
StatusUnpublished

This text of United States v. Sletten (United States v. Sletten) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Sletten, (10th Cir. 2026).

Opinion

Appellate Case: 25-1267 Document: 55-1 Date Filed: 06/02/2026 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT June 2, 2026 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 25-1267 (D.C. No. 1:10-CR-00225-JLK-1) MARCUS SLETTEN, (D. Colo.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT * _________________________________

Before HOLMES, Chief Judge, MATHESON, and FEDERICO, Circuit Judges. _________________________________

Marcus Sletten admitted to a fourth violation of his supervised-release

conditions. The district court revoked his supervised release and sentenced him to 24

months in prison. On appeal, Mr. Sletten contends the sentence is both procedurally

and substantively unreasonable. Exercising jurisdiction under 28 U.S.C. § 1291 and

18 U.S.C. § 3742(a), we affirm.

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 25-1267 Document: 55-1 Date Filed: 06/02/2026 Page: 2

I. BACKGROUND

In 2011, Mr. Sletten pled guilty to possession of child pornography in

violation of 18 U.S.C. § 2252A(a)(5)(B). The district court sentenced him to 100

months in prison followed by supervised release for life. Mr. Sletten started

supervised release in April 2018. Since then, he has repeatedly violated his

supervised release conditions, resulting in a cycle of release, violation, revocation,

and incarceration.

Prior Revocations

In October 2018, the district court first revoked Mr. Sletten’s supervised

release. Mr. Sletten admitted that he (1) failed to register his email account with the

police department and (2) violated the rules and restrictions at his sex offender

treatment program. At the revocation hearing, the court determined the United States

Sentencing Guidelines (“U.S.S.G.” or the “Guidelines”) advisory range was 6 to 12

months in prison. It sentenced him to 10 months. The court then stated, “This

defendant is going to be on supervised release for life, and the next time that there’s a

violation, it will be two years of a sentence, and after that if there’s another violation

it will still continue to be two years for each violation.” Aplt. Suppl. ROA, Vol. 3 at

21-22. Mr. Sletten served the custodial sentence and resumed supervised release in

June 2019.

In August 2019, the district court revoked Mr. Sletten’s supervised release

again. He admitted that he failed to follow his residential reentry center’s rules.

Despite the Guidelines range of 4 to 10 months in prison, the court sentenced him to

2 Appellate Case: 25-1267 Document: 55-1 Date Filed: 06/02/2026 Page: 3

24 months, noting that “at [Mr. Sletten’s] last revocation hearing I warned him that

the next time he violated his supervised release it would be a two-year sentence.”

Aplt. Suppl. ROA, Vol. 3 at 43. After completing his prison sentence, Mr. Sletten

resumed supervised release in March 2021.

In June 2023, the district court again revoked Mr. Sletten’s supervised release.

Mr. Sletten admitted that he (1) failed to install monitoring software on his cellphone,

(2) tested positive for alcohol, and (3) failed to provide drug-testing samples. The

court sentenced him to 18 months in prison, varying up from the 4-to-10 months

Guidelines range. Mr. Sletten resumed supervised release in July 2024.

Instant Revocation and Sentence

In February 2025, Mr. Sletten’s probation officer requested revocation of his

supervised release for the fourth time, alleging that he (1) failed to comply with a

search by refusing to provide the passcode to his smartphone; and (2) possessed an

unauthorized and unmonitored smartphone. Mr. Sletten admitted the violations.

After “consider[ing]” but rejecting the 4-to-10 months Guidelines range, the

district court said it had “no data” that supported the Guidelines recommendation.

ROA, Vol. 3 at 6-7. It then instructed the parties to focus on the 18 U.S.C. § 3553(a)

factors.

The Government requested 24 months in prison, the maximum statutory

sentence for Mr. Sletten’s revocation under § 3583(e)(3), and 55 years of supervised

release. Mr. Sletten’s counsel did not request a specific sentence but argued that

3 Appellate Case: 25-1267 Document: 55-1 Date Filed: 06/02/2026 Page: 4

incarceration would delay treatment that Mr. Sletten needed based on a recent autism

diagnosis.

Before imposing a sentence, the district court addressed the § 3553(a) factors

identified in § 3583(e) for supervised release revocations. 1 Starting with the nature

and circumstances of the offense and Mr. Sletten’s history and characteristics under

§ 3553(a)(1), the court recognized his recent autism diagnosis and need for treatment

but also considered that his supervised release violations “are many and repeated.”

ROA, Vol. 3 at 26. And it noted that Mr. Sletten’s underlying offense “victimizes

the most vulnerable people in our society.” Id. at 27.

Turning to § 3553(a)(2)’s need-for-the-sentence factor, the district court said

“protection of the public” was “one of [its] primary considerations” because

“[r]ecidivism is abounding in this case.” Id.; see 18 U.S.C. § 3553(a)(2)(C). Noting

that this was Mr. Sletten’s fourth violation, it said supervised release has been “an

utter failure to correct this behavior.” ROA, Vol. 3 at 26. The court expressed

concern about Mr. Sletten’s “repetition of violations” and “continued nonconformity”

1 Under 18 U.S.C. § 3583(e)(3), “The court may, after considering the factors set forth in section 3553(a)(1), (a)(2)(B), (a)(2)(C), (a)(2)(D), (a)(4), (a)(5), (a)(6), and (a)(7) . . . revoke a term of supervised release, and require the defendant to serve in prison all or part of the term of supervised release authorized by statute for the offense that resulted in such term of supervised release without credit for time previously served on postrelease supervision.”

4 Appellate Case: 25-1267 Document: 55-1 Date Filed: 06/02/2026 Page: 5

with his conditions. Id. at 27. Alluding to § 3553(a)(2)(B), the court said this case

may serve “as a deterrent for others,” Id. at 30. 2

For the kinds of sentences available and the Guidelines sentencing range,

§ 3553(a)(4), the district court noted the two-year statutory maximum for

Mr. Sletten’s supervised release violations and reiterated its reason for rejecting the

applicable Guidelines range. Id. at 28-29.

Addressing the need to avoid unwarranted sentence disparities under

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