Guy Collins, who was convicted in 2010 of conspiracy to distribute crack cocaine, sought early termination of his eight-year supervised release term three times. Collins had served 15 years in prison before beginning supervision in January 2022, with his sentence reduced under the First Step Act due to his exemplary prison record and rehabilitation efforts.
Circuit Judge Karen Nelson Moore ruled that the district court "abused its discretion" by mechanically applying its custom of denying early termination requests until defendants complete 50% of their supervised release. "A blanket rule, or custom, is not individualized," Moore wrote, emphasizing that decisions must flow from consideration of relevant sentencing factors under 18 U.S.C. ยง 3553(a).
The district court had initially acknowledged that "further supervision is necessary to afford adequate deterrence or to protect the public" in Collins's first motion, but later contradicted itself in the third denial without explanation. Collins appealed both the second and third denials after the court repeatedly cited its 50% custom as the primary basis for rejection.
The ruling joins similar decisions rejecting categorical time-served requirements for sentence modifications. The case highlights ongoing tensions between judicial efficiency customs and statutory mandates for individualized consideration in federal supervised release determinations.