Supervised Release Conditions Premature

Supervised Release Conditions Premature

By Christopher Zoukis
The Seventh Circuit Court of Appeals held it was premature to file a request to revise conditions of supervised release 14 years before those conditions were to go into effect.
The terse per curium ruling, issued on September 6, 2016, disallowed federal prisoner Andre Williams’ request to modify his conditions of supervised release. Supervised release is the federal version of parole, and by law the conditions imposed may be challenged in the district court “at any time” pursuant to 18 U.S.C. § 3583(e)(2).
The appellate court did not disagree that the law allows for such revisions. However, just because a court may act “at any time” to modify conditions of supervised release does not mean that it must.
The Court of Appeals agreed with the district court judge that “‘[Williams] may have totally other issues that he might want to deal with regarding supervised release’” in the 14 years between when his request was filed and when the conditions go into effect. The Court also noted that the laws governing conditions of supervised release could change between now and 2030, Williams’ projected release date.
The decision explained that it would have been improper for the district court to have proposed deferring a decision on the matter until after Williams was released, as “[he] is entitled to know, before he leaves prison, what terms and conditions govern his supervised release.”
In dicta, the Seventh Circuit suggested that it would be proper for a prisoner desiring to modify his conditions of supervised release to “make all potential arguments at one time in the year or so before release.” Williams represented himself pro se on appeal. See: United States v. Williams, 840 F.3d 865 (7th Cir. 2016).

Related legal case

United States v. Williams

This article originally appeared in Prison Legal News on June 9, 2017.
About Christopher Zoukis
Christopher Zoukis is an outspoken prisoner rights and correctional education advocate who is incarcerated at FCI Petersburg Medium in Virginia. He is an award-winning writer whose work has been published widely in major publications such as The Huffington Post, Prison Legal News, New York Daily News and various other print and online publications. Learn more about Christopher Zoukis at and