Jessie Paul Farmer was sentenced to the statutory maximum of 96 months in prison in 2016 after pleading guilty to two counts of using a communication facility to distribute methamphetamine. After his 2024 release, U.S. Chief District Judge Timothy L. Brooks found that Farmer had violated his supervised release conditions ten times — six failures to appear for drug testing and four positive drug tests between June and November 2024 — and sentenced him to an additional 12 months in prison, the maximum allowed under the supervised release statutes.
The Eighth Circuit panel rejected Farmer's argument that the revocation violated his Fifth and Sixth Amendment rights to jury trial and proof beyond a reasonable doubt. Chief Judge Colloton explained that the court was bound by Justice Breyer's controlling concurrence in United States v. Haymond, which 'agreed largely with the Haymond dissent and declined to transplant the Apprendi line of cases to the supervised-release context.' The court distinguished Farmer's case from the specific constitutional violation found in Haymond, which involved a statute requiring mandatory minimum sentences of at least five years for certain federal offenses.
The court emphasized the fundamental difference between Farmer's revocation and the problematic statute in Haymond, writing that unlike the Haymond provision, 'the application of § 3583(g) and § 3583(e) did not depend on Farmer's commission of a discrete set of federal criminal offenses.' Chief Judge Colloton noted that Farmer's violations — drug test failures and positive results — 'none of which necessarily rises to the level of a federal criminal offense,' were procedural violations rather than new crimes.
Farmer had initially argued in district court that because he received the maximum sentence for his original conviction, any additional imprisonment based on supervised release violations should require jury findings beyond a reasonable doubt under the Supreme Court's Apprendi doctrine. The district court denied his motion to dismiss, and the violation findings were made by a preponderance of the evidence standard rather than the beyond-a-reasonable-doubt standard Farmer sought.
The circuit court rejected Farmer's reliance on the Haymond plurality opinion, explaining that 'the Haymond plurality opinion does not state the governing rule' and that the court applies 'the rule of Justice Breyer's concurrence.' Chief Judge Colloton wrote that the statutes governing Farmer's case preserved judicial discretion, noting that '§ 3583(e)(3) affords the court discretion to set a term as short as one day and anywhere up to the maximum term of supervised release authorized by statute for the original offense of conviction.'
The decision reinforces the Eighth Circuit's consistent application of the narrow Haymond ruling, following the court's precedents in United States v. Childs and United States v. Watters. Chief Judge Colloton emphasized that revocation sentences under § 3583(e)(3) are fundamentally different from the problematic statute in Haymond because they 'restrict the term of additional imprisonment based on the seriousness of the underlying offense' rather than imposing uniform mandatory minimums regardless of the original crime.
The ruling provides clarity for supervised release proceedings in the Eighth Circuit, confirming that traditional revocation procedures remain constitutionally permissible even when they result in additional prison time. The court concluded that 'a revocation sentence under § 3583(e) is part of the penalty for the initial offense' rather than punishment for a new crime, preserving the historical distinction between original sentencing and supervised release enforcement that has governed federal probation systems.