Breach of Trust, Treatment Alternatives, and Appellate Deference in Supervised Release Revocations: Commentary on United States v. Steele (4th Cir. 2025)

Breach of Trust, Treatment Alternatives, and Appellate Deference in Supervised Release Revocations: Commentary on United States v. Steele (4th Cir. 2025)

I. Introduction

The Fourth Circuit’s unpublished per curiam decision in United States v. Alexander Clarance Steele, No. 25‑4108 (4th Cir. Dec. 8, 2025), sits at the intersection of three recurring themes in federal supervised release practice:

  • the breadth of district court discretion when sentencing upon revocation,
  • the tension between sanctioning “breach of trust” and addressing substance use disorders through treatment, and
  • the level of explanation required when a district court rejects a defendant’s proposed alternative—here, an in‑custody drug‑treatment program, the “Alpha program.”

Although the opinion is unpublished and explicitly “not binding precedent in this circuit,” it offers a clear and compact reaffirmation of several important principles: (1) the highly deferential “plainly unreasonable” standard of appellate review for revocation sentences; (2) the presumption of reasonableness for sentences within the Chapter Seven policy statement range; (3) the primacy of “breach of trust” as the organizing concept in supervised release revocation; and (4) the limited—but real—duty of reason-giving when a court rejects a defendant’s treatment‑based alternative proposal.

This commentary examines the opinion in detail, with particular attention to how the Fourth Circuit uses its own precedents to reinforce district court discretion in cases where a defendant’s substance use disorder both motivates violations and underlies requests for additional treatment instead of incarceration.

II. Background and Procedural History

A. Underlying Conviction and Sentence

Alexander Clarance Steele pled guilty to one count of:

  • conspiracy to possess with intent to distribute, and to distribute, 50 grams or more of methamphetamine, in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(B), and 846.

The district court (W.D. Va., Chief Judge Elizabeth K. Dillon) sentenced Steele to:

  • 120 months’ (10 years) imprisonment, and
  • 4 years of supervised release.

B. Supervised Release Violations and Initial Revocation Proceedings

Before his four‑year term of supervised release expired, Steele’s probation officer petitioned to revoke supervision. The petition alleged multiple violations:

  • use of controlled substances on two occasions, and
  • failure to follow the probation officer’s instructions, including instructions to complete a substance abuse assessment.

Initially, Steele was detained pending the revocation hearing. A magistrate judge later released him on bond subject to several conditions, most notably:

  • He would be released directly to Pyramid Healthcare (“Pyramid”), a residential substance abuse treatment facility.
  • He would remain at Pyramid for at least 30 days and complete the program.
  • He would not leave Pyramid without court permission.

One day after arriving at Pyramid, Steele left without court authorization. The probation officer then petitioned for a warrant based on this new violation. Steele was arrested, his bond was revoked, and he was ordered detained pending the supervised release revocation hearing after the magistrate judge found a violation of his bond conditions.

C. Admission of Violations and Revocation Sentence

At the supervised release revocation hearing, Steele admitted that he:

  • used controlled substances on two occasions while on supervision,
  • failed to follow his probation officer’s instructions (including the requirement to complete a substance abuse assessment), and
  • left Pyramid one day after arrival without permission.

The district court:

  • calculated an advisory Chapter Seven policy statement range of 18–24 months’ imprisonment under the 2024 Guidelines,
  • revoked Steele’s supervised release, and
  • imposed a sentence of 18 months’ imprisonment plus 2 years of supervised release.

D. The “Alpha Program Proposal”

The central dispute on appeal arose from Steele’s proposed alternative to immediate revocation and imprisonment. Steele asked the district court to:

  1. defer ruling on the revocation (essentially hold the matter in abeyance),
  2. order him into a four‑month substance abuse treatment program, the “Alpha program,” conducted within the jail where he was being held, and
  3. reconvene after four months for a renewed revocation hearing, at which the court could reassess whether revocation and further imprisonment were necessary.

Collectively, the opinion refers to this as the “Alpha program proposal.”

E. Issues on Appeal

On appeal, Steele did not challenge revocation itself; he focused solely on the 18‑month term of imprisonment. He argued that the sentence was both procedurally and substantively unreasonable, and therefore “plainly unreasonable,” on three main grounds:

  1. Procedural reasonableness – inadequacy of explanation: He contended that the district court failed adequately to explain why it rejected the Alpha program proposal.
  2. Procedural reasonableness – misunderstanding of authority and factual findings: He asserted that the district court:
    • may have mistakenly believed it lacked authority to adopt the Alpha program proposal, and
    • clearly erred by finding his commitment to rehabilitation not genuine and by characterizing his earlier request to enter Pyramid as a “ruse.”
  3. Substantive reasonableness: He argued the 18‑month term:
    • overemphasized the need to sanction breach of trust while underweighting the need to provide effective correctional treatment, and
    • was greater than necessary given the role his substance use disorder played in the underlying violations.

Steele further asserted that the district court’s errors were “plain,” dovetailing his arguments with the “plainly unreasonable” review standard.

III. Summary of the Fourth Circuit’s Opinion

The Fourth Circuit affirmed the revocation judgment and the 18‑month sentence. Its holding can be summarized as follows:

  • Standard of review: The court reiterated that revocation sentences are reviewed under a deferential two‑step framework, asking first whether the sentence is procedurally or substantively unreasonable and only then, if it is unreasonable, whether the unreasonableness is “plainly” (i.e., clearly or obviously) so.
  • No procedural unreasonableness: The court held that:
    • The district court provided an adequate explanation for its decision, and its reasons for rejecting the Alpha program proposal were clearly linked to permissible factors (nature and circumstances of the violations, Steele’s history and characteristics, and the need to sanction breach of trust).
    • Nothing in the record indicated that the district court misunderstood or doubted its authority to implement the Alpha program proposal.
    • The district court did not clearly err in finding Steele’s apparent interest in rehabilitation not genuine and viewing his earlier request to attend Pyramid as a ruse, particularly when weighed against his pattern of non‑compliance and his leaving Pyramid after one day.
  • No substantive unreasonableness: The court found the 18‑month sentence substantively reasonable because:
    • It fell within the advisory policy statement range and was therefore presumptively reasonable.
    • The district court appropriately weighed the § 3553(a) factors that 18 U.S.C. § 3583(e) makes relevant, with particular focus on Steele’s repeated breaches of trust and his conduct when offered treatment opportunities.
    • The court did not improperly ignore Steele’s substance use disorder or his interest in treatment; rather, it balanced those considerations against his history of non‑compliance and resistance to treatment while on release.
    • Steele’s disagreement with the district court’s weighing of the factors did not suffice to show substantive unreasonableness.
  • No need to reach “plainly unreasonable” step: Because the panel found the sentence neither procedurally nor substantively unreasonable, it had no cause to decide whether any unreasonableness was “plain.” Accordingly, the court affirmed without reaching that second step.

IV. Detailed Analysis

A. The Standard of Review: “Plainly Unreasonable” and Appellate Deference

The Fourth Circuit frames revocation sentencing review through its settled “plainly unreasonable” rubric, citing United States v. Patterson, 957 F.3d 426 (4th Cir. 2020), and United States v. Padgett, 788 F.3d 370 (4th Cir. 2015). The opinion reproduces the core standard:

“A district court has broad discretion when imposing a sentence upon revocation of supervised release. This [c]ourt will affirm a revocation sentence if it is within the statutory maximum and is not plainly unreasonable.” (Patterson, 957 F.3d at 436.)

The review process is explicitly two‑step:

  1. Determine whether the sentence is procedurally or substantively unreasonable, applying “the same procedural and substantive considerations that guide [its] review of original sentences,” but in “a more deferential appellate posture” (Padgett, 788 F.3d at 373).
  2. If the sentence is unreasonable, decide whether it is “plainly unreasonable”—that is, whether its unreasonableness is “clear or obvious.” Patterson, 957 F.3d at 437.

This framework is distinct from (though conceptually analogous to) the plain‑error standard under Federal Rule of Criminal Procedure 52(b). The opinion carefully maintains separation: it speaks only in the terms of “plainly unreasonable” and does not transform Steele’s “plain error” language into a Rule 52 analysis. Instead, because the panel finds no error—procedural or substantive—its inquiry stops at step one.

The key takeaway is that appellate courts in the Fourth Circuit give district courts even greater deference in revocation sentencing than in original sentencing, with the added protection that within‑range revocation sentences are presumed reasonable. That theme pervades the court’s rejection of each of Steele’s arguments.

B. Procedural Reasonableness: Explanation and Treatment Alternatives

1. Explanation Requirement – Slappy and Gibbs

A revocation sentence is procedurally reasonable if the district court:

  • considers the advisory Chapter Seven policy statements and the applicable § 3553(a) factors that § 3583(e) makes relevant, and
  • “adequately explains the chosen sentence.” United States v. Coston, 964 F.3d 289, 297 (4th Cir. 2020).

The Fourth Circuit reiterates that, under United States v. Slappy, 872 F.3d 202 (4th Cir. 2017), the explanation need not be as detailed as in an original sentencing:

“although the court need not be as detailed or specific when imposing a revocation sentence as it must be when imposing a post-conviction sentence, it still must provide a statement of reasons for the sentence imposed.” (internal quotation marks omitted).

And as United States v. Gibbs, 897 F.3d 199 (4th Cir. 2018), teaches, the minimum requirement is that the explanation be sufficient:

“to permit meaningful appellate review with the assurance that the court considered any potentially meritorious arguments raised by [the defendant] with regard to his sentencing.” (internal quotation marks, emphasis, and brackets omitted).

Applied to Steele, the appellate court concludes that the district court met this standard. Although the per curiam opinion does not reproduce the district court’s full explanation, it characterizes that explanation in several critical ways:

  • The court “heard and considered Steele’s arguments made in support of the Alpha program proposal.”
  • The reasons given for rejecting the proposal “are easily matched to factors appropriate for consideration in the revocation sentencing context and are tied to Steele’s particular situation.”

Those reasons specifically referenced:

  • “the nature and circumstances of his violative conduct,”
  • “his history and characteristics,” and
  • “the sanctioning of his acts in breaching trust while on release.”

These fit squarely within 18 U.S.C. § 3553(a)(1) and § 3583(e), and they echo the Guidelines’ Chapter Seven commentary emphasizing that, “at revocation the [district] court should sanction primarily the defendant's breach of trust.” (USSG ch. 7, pt. A, introductory cmt. 3(b)).

The opinion thus sends a clear message: where the record reflects that the court:

  • listened to the defendant’s alternative proposal,
  • engaged with the core facts (here, repeated violations and failure to seize earlier treatment opportunities), and
  • grounded its decision in statutory factors and the breach‑of‑trust concept,

a more elaborate written or oral explanation is not required to survive procedural reasonableness review, especially in the revocation context.

2. Alleged Misunderstanding of Authority

Steele argued that the district court “may have incorrectly believed that it lacked the authority to implement the Alpha program proposal.” The Fourth Circuit rejects this outright:

“Nothing in the court's comments explaining its sentencing decision suggests it believed it lacked the authority to implement the Alpha program proposal.”

This is a significant, if quiet, holding. It underscores two practical points:

  1. Burden on the appellant: A defendant who claims the court misunderstood its legal authority must point to something concrete in the record. Mere speculation that the court might have believed it lacked power to adopt an alternative is insufficient.
  2. Silence is usually not error: The court does not require district judges, when rejecting a defense proposal, to affirmatively state “I have the authority to do this, but I decline.” Absent contrary indications, appellate courts will presume the judge understood and exercised discretion.

In practice, this means that unless the transcript contains statements such as “I cannot do that” or similar misstatements of law, the Fourth Circuit will not infer a misunderstanding of authority from the mere fact that the court chose not to adopt the defendant’s alternative.

3. Characterizing the Alpha Proposal and Pyramid Request

The district court found that:

  • Steele’s “interest in rehabilitation appeared not to be genuine,” and
  • his earlier request to attend Pyramid “appeared to be a ruse.”

Steele challenged these findings as both factually and procedurally problematic. The Fourth Circuit’s treatment of these findings dovetails with its discussion of factual deference (addressed more fully below), but it also matters for procedural reasonableness: an explanation that rests on clearly erroneous factual premises might be procedurally flawed.

Here, however, the appellate court concludes that no clear error occurred, because the inference drawn by the district court—skepticism toward Steele’s motives—is supported by the record:

  • Steele twice used controlled substances while on supervised release.
  • He refused to follow probation’s instructions to complete a substance abuse assessment.
  • He left Pyramid after one day, contrary to explicit court conditions.
  • He sought out treatment and programming only after being reincarcerated and facing additional prison time.

These facts provide a sufficient basis—though not the only possible one—for the district court’s skepticism. Thus, the findings are not clearly erroneous, and they can validly support the sentencing explanation.

C. Substantive Reasonableness: Breach of Trust vs Rehabilitation

1. Presumption of Reasonableness for Within‑Range Sentences

The Fourth Circuit, citing Padgett, restates a critical appellate principle:

“A sentence within the policy statement range is presumed reasonable, though the sentencing court retains broad discretion to impose a term of imprisonment up to the statutory maximum.”

Steele’s 18‑month sentence was:

  • within the applicable policy statement range of 18–24 months, and
  • well below the statutory maximum for his offense class.

Under this presumption, the burden shifted to Steele to demonstrate that his within‑range sentence was nonetheless unreasonable in light of the totality of the circumstances.

2. Weighting of § 3553(a) Factors – Jeffery and Friend

The opinion emphasizes that district courts enjoy “extremely broad discretion when determining the weight to be given each of the § 3553(a) factors,” quoting United States v. Jeffery, 631 F.3d 669, 679 (4th Cir. 2011).

At the same time, United States v. Friend, 2 F.4th 369 (4th Cir. 2021), teaches that a court may not exclusively focus on a single consideration. But they may give strong weight to some factors over others, so long as:

  • they remain within the scope of permissible factors under § 3583(e), and
  • the overall explanation reflects a balancing rather than a single‑factor fixation.

The Fourth Circuit holds that this standard was satisfied in Steele’s case:

  • The district court properly emphasized “Steele’s conduct when afforded opportunities to participate in drug treatment and his repeated breaches of trust,” including his drug use on release.
  • The court clearly understood that Steele suffered from a “substance use disorder” and even “calibrated its sentencing determination to reflect Steele’s conduct in participating in rehabilitative programming.”
  • Nevertheless, the district court reasonably concluded that the Alpha program’s four‑month jail treatment component, by itself, would not sufficiently address the seriousness of Steele’s repeated non‑compliance and his quick abandonment of prior treatment.

Steele’s argument largely amounted to a claim that the court should have given more weight to the goal of providing effective treatment. The Fourth Circuit, echoing Friend, rejects the notion that such a disagreement about weight equates to unreasonableness:

“a defendant's mere disagreement with the district court's weighing of the sentencing factors is not enough to find the sentence . . . unreasonable.” (Friend, 2 F.4th at 381.)

3. Breach of Trust as the Central Revocation Rationale

The opinion draws directly from the Guidelines’ Chapter Seven commentary:

“[A]t revocation the [district] court should sanction primarily the defendant's breach of trust.” USSG ch. 7, pt. A, introductory cmt. 3(b).

By foregrounding this language, the Fourth Circuit:

  • underscores that revocation sentencing is conceptually distinct from original sentencing; the focus is not the original crime, but the supervised release behavior and the breach of the court’s trust, and
  • justifies the district court’s heavy emphasis on Steele’s violations—drug use, disobedience of treatment instructions, flight from Pyramid—rather than his underlying addiction alone.

The panel concludes that, under “the totality of the circumstances,” the 18‑month sentence was substantively reasonable, especially given the strong breach‑of‑trust rationale and Steele’s pattern of failing to comply even when given non‑custodial treatment opportunities.

D. Factual Findings and Clear Error Review – Cox

The Fourth Circuit reiterates the bifurcated standard for reviewing a district court’s “findings supporting a chosen sentence”:

  • Legal conclusions are reviewed de novo.
  • Factual findings are reviewed for clear error. United States v. Cox, 744 F.3d 305, 308 (4th Cir. 2014).

“Clear error” occurs when the reviewing court is left with the “definite and firm conviction that a mistake has been committed.” The panel applies this test to Steele’s challenge to the district court’s findings about his sincerity and motives.

In affirming, the panel signals a high level of deference to district judges’ credibility assessments and inferences about a defendant’s motives, especially where those inferences are grounded in:

  • observed behavior over time (repeated positive drug tests, ignoring instructions), and
  • the timing of rehabilitative efforts (seeking treatment only after facing new imprisonment).

The court’s approach here is instructive for future cases: as long as the district court’s inferences are rationally tied to the record, an appellate court will rarely disturb them on clear‑error review—even when reasonable alternative interpretations of the same facts are possible.

E. Treatment Alternatives and the Scope of District Court Discretion

The heart of Steele’s appeal was his contention that the district court should have pursued a “treatment‑first, revocation‑later” model by adopting the Alpha program proposal. The Fourth Circuit’s decision clarifies several practical points about such proposals:

  1. Authority vs. obligation: District courts generally have statutory authority, under § 3583(e), to modify conditions, extend terms, or revoke supervised release, and they may incorporate programmatic treatment as part of their approach. But they are not obligated to defer revocation or to adopt any specific treatment program even if one is available and arguably suitable.
  2. Appellate respect for trial‑level risk assessment: Judges at the revocation stage are making predictive judgments about risk, compliance, and sincerity. Here, the district court assessed Steele as someone who had already failed to comply with treatment‑related conditions while at liberty. The Fourth Circuit defers to that assessment when the record supports it.
  3. Limited explanation demanded for rejecting alternatives: The court’s explanation here was not elaborate. But because it tied the rejection of the Alpha program to:
    • the nature of Steele’s violations,
    • his past failures in treatment settings, and
    • his breach of trust,
    it sufficed. Appellate courts will not require district judges to give a granular, point‑by‑point refutation of every alternative proposed.
  4. Role of in‑custody programs: The opinion implicitly recognizes that programs like the Alpha program are valid options, but confirms they remain discretionary tools, not rights. Defendants can urge them as an alternative; courts must consider the proposal; but rejection of such a program, by itself, does not render a sentence unreasonable.

V. Precedents Cited and Their Influence

The opinion is heavily anchored in prior Fourth Circuit case law. Each cited case serves a distinct function in the court’s reasoning.

A. United States v. Patterson, 957 F.3d 426 (4th Cir. 2020)

Patterson is the primary authority for the overarching standard: revocation sentences are affirmed if within the statutory maximum and not “plainly unreasonable.” It also provides the articulation of the “plainly unreasonable” two‑step inquiry and underscores the breadth of district court discretion at revocation.

In Steele, Patterson supports:

  • the deferential posture of appellate review, and
  • the notion that district courts have “broad discretion” in revocation sentencing outcomes.

B. United States v. Padgett, 788 F.3d 370 (4th Cir. 2015)

Padgett is foundational for:

  • the concept that standard sentencing reasonableness principles apply to revocation, albeit “more deferentially,” and
  • the presumption that a sentence within the Chapter Seven policy statement range is reasonable.

In Steele, this presumption is pivotal: because the sentence is within the 18‑24‑month range, it starts from a position of appellate strength that the defendant must overcome.

C. United States v. Coston, 964 F.3d 289 (4th Cir. 2020)

Coston clarifies what makes a revocation sentence procedurally reasonable: the need to consider Chapter Seven and applicable § 3553(a) factors and to articulate a minimally adequate explanation.

The Steele panel uses Coston to frame its inquiry into whether the district court:

  • engaged with the correct sources of guidance (Chapter Seven and § 3553(a)/§ 3583(e)), and
  • explained its rationale enough to allow appellate review.

D. United States v. Slappy, 872 F.3d 202 (4th Cir. 2017)

Slappy is cited for the proposition that the explanation requirement is relaxed—but not eliminated—at revocation. The district court must give a “statement of reasons” but need not mirror the detail of an initial sentencing.

In Steele, this standard allows the panel to accept a relatively concise explanation, as long as:

  • the court’s reasons can be “easily matched” to permissible factors, and
  • they appear tailored to the defendant’s particular circumstances.

E. United States v. Gibbs, 897 F.3d 199 (4th Cir. 2018)

Gibbs elaborates on what it means for a court to consider the defendant’s “potentially meritorious arguments.” The explanation must be sufficient for the appellate court to be confident those arguments were not ignored.

In Steele, the Alpha program proposal is such an argument. The panel finds that the record reflects adequate consideration, thus satisfying Gibbs.

F. United States v. Cox, 744 F.3d 305 (4th Cir. 2014)

Cox provides the clear‑error standard used to evaluate the district court’s factual findings about Steele’s sincerity and motives. By citing Cox, the panel signals strict adherence to a deferential view of factual review at sentencing, particularly concerning credibility and intent.

G. United States v. Jeffery, 631 F.3d 669 (4th Cir. 2011)

Jeffery establishes that district courts hold “extremely broad discretion” in assigning weight to statutory sentencing factors. This is central to rejecting Steele’s substantive reasonableness challenge: he cannot show error simply because he would have weighed treatment considerations more heavily.

H. United States v. Friend, 2 F.4th 369 (4th Cir. 2021)

Friend makes two important points:

  • Courts may not exclusively rely on one sentencing factor to the exclusion of all others.
  • However, a defendant’s disagreement with how those factors are balanced does not make a sentence unreasonable.

In Steele, Friend is used both as a limit on overly narrow rationales and as a shield: because the district court here:

  • did not rely only on breach of trust, but also acknowledged Steele’s substance use disorder and his participation in programming, and
  • simply placed more weight on repeated violations and risk,

its balancing passes muster.

VI. Complex Concepts Simplified

For clarity, it is helpful to briefly translate several key legal concepts used in the opinion.

1. “Procedurally Reasonable” vs. “Substantively Reasonable”

  • Procedurally reasonable: Did the judge:
    • calculate the advisory range correctly,
    • consider the proper statutory factors,
    • listen to and consider the parties’ arguments, and
    • adequately explain the sentence?
  • Substantively reasonable: Is the length and type of sentence reasonable, given the totality of the circumstances and the allowable sentencing factors?

2. “Plainly Unreasonable”

This is a special standard for supervised release revocation sentences in the Fourth Circuit. A sentence is “plainly unreasonable” only if:

  1. it is procedurally or substantively unreasonable and
  2. the unreasonableness is “clear or obvious.”

If the appellate court finds the sentence reasonable, it never reaches the second step.

3. Chapter Seven “Policy Statement Range”

Unlike the Sentencing Guidelines for initial sentencings, the revocation provisions in Chapter Seven are formally “policy statements.” But in practice, courts treat the recommended range as an important advisory benchmark. A sentence within that range is “presumed reasonable” on appeal in the Fourth Circuit.

4. “Breach of Trust”

In the supervised release context, “breach of trust” captures the idea that:

  • the court granted the defendant a conditional freedom (supervised release) in lieu of continued incarceration,
  • the defendant violated those conditions, and
  • revocation is meant primarily to respond to this breach of the court’s trust, not to re‑punish the original crime.

This concept explains why repeated non‑compliance, especially with treatment‑related conditions, often justifies prison terms at revocation even where the underlying violations are themselves non‑violent or linked to addiction.

5. “Clear Error”

Clear error review asks whether the appellate court, reviewing the whole record, is left with a “definite and firm conviction” that the district court was mistaken about a factual issue. If reasonable people could see the facts either way, the finding stands—even if the appellate judges might personally have seen it differently.

6. The Alpha Program Proposal

The Alpha program is a jail‑based, four‑month treatment program. Steele’s proposal was procedural and remedial:

  • Rather than immediately revoke and impose a prison term, the court would defer its ruling and order him into Alpha.
  • After four months, the court would re‑evaluate whether to revoke and what sentence to impose.

Nothing in the opinion suggests that such a structure is impermissible. Rather, the court holds that the district judge was not obligated to adopt it and acted reasonably in declining to do so.

VII. Impact and Practical Implications

A. For District Judges

The opinion reinforces that:

  • Judges retain very broad discretion at revocation, especially where they:
    • identify and apply the correct legal framework (Chapter Seven, § 3553(a), § 3583(e)),
    • articulate reasons connected to the defendant’s specific conduct and history, and
    • link their rationale to the breach‑of‑trust concept.
  • They are not required to adopt, or provide elaborate justifications for rejecting, every proposed treatment alternative, so long as the record shows consideration and a reasoned basis for rejection.
  • They may, consistent with Jeffery and Friend, assign heavy weight to breach of trust and repeated non‑compliance, even when addiction is a driving factor in the violations.

B. For Defense Counsel

Defense attorneys advocating for treatment‑based alternatives to revocation can draw several lessons:

  • It is critical to build a record that demonstrates not only the availability of a program, but also the defendant’s prior success in similar settings or credible new reasons to believe compliance will be different this time.
  • Where a court rejects an alternative, counsel should consider asking the judge—respectfully—to clarify whether the rejection is:
    • based on legal limits (lack of authority), or
    • based on discretion (judging it inappropriate under the facts).
    This can create an appellate record for, or foreclose, later claims of misunderstood authority.
  • On appeal, arguments that a within‑range sentence is unreasonable face a steep uphill climb; counsel must show more than disagreement with factor‑balancing.

C. For Probation Officers and Prosecutors

For probation and the government, Steele is a persuasive reaffirmation that:

  • Courts may legitimately view repeated non‑compliance with supervision and prior treatment orders as strong evidence of breach of trust warranting prison time.
  • Evidence of renewed interest in treatment that materializes only after re‑incarceration can reasonably be viewed skeptically.
  • So long as the district court pays attention to treatment options and the defendant’s condition, it is not error to conclude that further treatment efforts should be accompanied—or replaced—by a term of incarceration.

D. Systemic Implications

More broadly, Steele highlights the structural tension in revocation sentencing for individuals with substance use disorders:

  • On one hand, courts are encouraged to consider “the need for the sentence imposed . . . to provide the defendant with needed . . . medical care, or other correctional treatment in the most effective manner.” (§ 3553(a)(2)(D)).
  • On the other hand, the Guidelines explicitly task courts at revocation with prioritizing breach of trust and public safety, not just treatment.

Steele does not resolve that tension; it instead confirms that, at least in the Fourth Circuit, district judges have very wide latitude to decide how to navigate it, and appellate oversight will be limited to clear deviations from reason or law.

VIII. Conclusion

United States v. Steele does not create new binding law, but it crystallizes and applies several important, recurring principles in supervised release jurisprudence:

  • Revocation sentences are examined under a deferential “plainly unreasonable” standard, and within‑range sentences carry a presumption of reasonableness.
  • District courts need not provide elaborate explanations at revocation, but they must connect their reasoning to the applicable statutory factors and to the specific facts of the case.
  • “Breach of trust” remains the central organizing principle of revocation sentencing, and courts may permissibly give that concept substantial weight, even where addiction is a driving factor in the violations.
  • Defendants may propose treatment‑based alternatives—such as the Alpha program proposal—but district courts retain broad discretion to decline such alternatives, particularly when the defendant has a history of failed compliance with prior treatment and supervision conditions.
  • Appellate courts will rarely disturb district courts’ credibility assessments and inferences about a defendant’s sincerity in seeking rehabilitation, so long as those assessments are grounded in the record.

In the broader legal context, Steele is a reminder that, in the revocation arena, appellate scrutiny is intentionally limited. The key practical message is directed to trial judges and litigants alike: build a clear, grounded record that ties sentencing decisions—whether in favor of treatment, incarceration, or a combination—to the defendant’s individualized conduct, history, and the statutory framework. If that is done, appellate courts in the Fourth Circuit are likely to affirm.

Case Details

Year: 2025
Court: Court of Appeals for the Fourth Circuit

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