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Criminal Law-Supervised Release-Revocation-Use of Improper Factor

Staff Report//July 22, 2026//

Criminal Law-Supervised Release-Revocation-Use of Improper Factor

Staff Report//July 22, 2026//

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Defendant appealed the sentence imposed following the revocation of his supervised release, arguing that the district court relied on an improper factor – his original offense – as a key reason for his sentence.  

Where the district court’s comments demonstrated that it was focused on the nature of defendant’s violation rather than his original offense that resulted in his supervised release, the district court had not relied on an improper factor.  

Judgment is affirmed. 

U.S. v. Salean (MLW No. 85107/Case No. 24-2869 – 4 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of Minnesota, Brasel, J. 

 

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