Breach-of-Trust Sentencing After Esteras: Serious Violation Conduct May Be Considered for Deterrence/Public Protection, and No-Contact Conditions with Romantic Partners May Stand

Case: United States v. Terrell Lamar Williams (6th Cir. Mar. 13, 2026)  |  Court: United States Court of Appeals for the Sixth Circuit  |  Disposition: Affirmed

I. Introduction

This recommended-for-publication Sixth Circuit decision addresses two recurring questions in supervised-release revocation practice: (1) what a district court may consider when selecting a revocation sentence after the Supreme Court’s recent limitation on “retribution” in revocation proceedings; and (2) when a district court may impose a supervised-release condition restricting contact with a romantic partner, even where the defendant invokes the constitutional right to marry.

The defendant, Terrell Lamar Williams, was serving a five-year term of supervised release following a below-Guidelines sentence for conspiracy to distribute cocaine. During supervision, he (as found by the district court) engaged in a multi-year scam persuading an older woman (R.A.) to send money based on fabricated kidnapping-and-ransom narratives, concealed ongoing drug use by faking urine tests, and drove with a suspended license. The district court revoked supervision, imposed an above-Guidelines 30-month prison term, ordered a new five-year term of supervised release, and added a condition barring contact with his longtime girlfriend, S.H., who the court found assisted the fraud and who had received violent threats from Williams.

On appeal, Williams argued that the district court impermissibly punished the violation conduct itself (especially the fraud), imposed a substantively unreasonable sentence by overweighting the seriousness of the violation conduct, and unlawfully burdened his right to marry by restricting contact with S.H.

II. Summary of the Opinion

III. Analysis

A. Precedents Cited (and How They Shaped the Decision)

1. Standards of review and issue preservation

• United States v. Price (901 F.3d 746, 749 (6th Cir. 2018)) supplied the baseline: revocation sentences are ordinarily reviewed for abuse of discretion.
• United States v. Vonner (516 F.3d 382, 385–86 (6th Cir. 2008) (en banc)) provided the preservation rule that shifted part of the appeal to plain-error review when Williams failed to raise a specific procedural objection after being invited to object. This mattered because it raised Williams’s burden from showing “mere error” to showing “plain” (obvious) error plus prejudice and harm to the integrity of proceedings.
• United States v. Parrish (915 F.3d 1043, 1048 (6th Cir. 2019)) framed the “impermissible factor” argument as procedural, not substantive—channeling the claim into plain-error review under Vonner.

2. The “breach of trust” theory and its compatibility with the retribution bar

• United States v. Morris (71 F.4th 475, 482 (6th Cir. 2023)) anchored the core revocation concept: while courts may not “punish” the new criminal conduct as such, they may “sanction the defendant’s breach of trust associated with the violation.” The panel used Morris to justify treating the seriousness of violation conduct as evidence of the magnitude of the breach of trust.
• United States v. Patterson (158 F.4th 700, 703 n.2 (6th Cir. 2025) (citing Esteras v. United States, 606 U.S. 185, 194 n.5 (2025))) provided the doctrinal backdrop: after Esteras, district courts “can’t consider retribution when revoking supervised release.” Williams tried to leverage that limitation into a broader prohibition on referencing serious violation conduct.
• Esteras v. United States (606 U.S. 185, 194 n.5 (2025)) was treated as setting a boundary (no retribution) rather than collapsing revocation sentencing into an artificial blindness to the real-world severity of violations. The panel’s move was to distinguish “retribution” from “breach of trust” and from forward-looking goals (deterrence and public protection).
• United States v. Hunter (No. 25-3069, 2025 WL 3731056, at *3–5 (6th Cir. Dec. 26, 2025) (Thapar, J., concurring in the judgment)) supplied the conceptual bridge: breach of trust is “forward-looking,” rooted in the supervisory relationship and reintegration, rather than backward-looking punishment for its own sake. The Williams panel relied heavily on that articulation to reconcile breach-of-trust reasoning with Esteras.
• United States v. Johnson (529 U.S. 53, 59 (2000)) was cited for the institutional premise that supervision depends on a trust relationship among courts, probation, and defendants—making “breach” a natural and legitimate revocation lens.
• United States v. Johnson (640 F.3d 195, 207 (6th Cir. 2011)) supported treating breach of trust as part of “history and characteristics” under § 3553(a)(1), which is incorporated into revocation sentencing by § 3583(e).
• United States v. Blackman (No. 24-5517, 2025 WL 1262322, at *3 (6th Cir. May 1, 2025)) reinforced the panel’s point that returning to illegality shows the need for deterrence and public protection—two considerations expressly allowed by § 3583(e) via § 3553(a)(2)(B)–(C).

3. Substantive reasonableness and deference to factor weighing

• United States v. Vowell (516 F.3d 503, 512 (6th Cir. 2008)) framed substantive reasonableness (“sufficient but not greater than necessary”).
• United States v. Rayyan (885 F.3d 436, 442 (6th Cir. 2018)) and United States v. Houston (529 F.3d 743, 756 (6th Cir. 2008)) emphasized that appellate courts do not reweigh sentencing factors and that weighing is not a mathematical formula—supporting affirmance even where the sentence is above the advisory range.
• United States v. Mickel (No. 24-1247, 2025 WL 263390, at *2 (6th Cir. Jan. 22, 2025)) bolstered the district court’s reliance on Williams’s prior below-Guidelines leniency: earlier lenience reflects trust; a later breach may justify an upward variance at revocation.

4. Special conditions restricting intimate association / marriage-related claims

• United States v. Nixon (664 F.3d 624, 627 (6th Cir. 2011)) supplied the governing three-part test for special supervised-release conditions: reasonable relation to sentencing factors, no greater deprivation than necessary, and consistency with Sentencing Commission policy statements.
• United States v. Kingsley (241 F.3d 828, 839 n.15 (6th Cir. 2001)) added that when a condition limits a fundamental constitutional right, it must be directly related to rehabilitation and public protection.
• United States v. Faber (718 F. App'x 349, 351–52 (6th Cir. 2017)) was used as a “collecting” citation for Sixth Circuit willingness to uphold no-contact restrictions involving romantic partners when justified by safety/recidivism concerns.
• United States v. Bortels (962 F.2d 558, 559 (6th Cir. 1992) (per curiam)) provided a concrete analog: barring association with a fiancé where the partner relationship facilitated dangerous/obstructive conduct (there, protection from arrest).
• United States v. Brandenburg (157 F. App'x 875, 879–80 (6th Cir. 2005)) and United States v. Horn (No. 25-3147, 2025 WL 3070315, at *3–4 (6th Cir. Nov. 3, 2025)) supported restrictions involving romantic partners in domestic-violence contexts—here mapped onto Williams’s threats to kill S.H.
• United States v. Shultz (733 F.3d 616, 623 (6th Cir. 2013)) supported the proposition that a condition is less liberty-restrictive where the defendant may seek probation-officer permission for contact.
• United States v. Arnold (549 F. App'x 491, 498 (6th Cir. 2013)) and 18 U.S.C. § 3583(e)(2) supported the availability of later modification or removal, further reducing the condition’s constitutional bite.

B. Legal Reasoning

1. Distinguishing “punishment for new conduct” from “sanctioning breach of trust”

Williams’s principal legal move was to characterize the district court’s discussion of the fraud’s seriousness as impermissible punishment for the underlying conduct. The panel rejected that characterization on the record: the district court tied the facts to permissible purposes—“deterrence and protecting the public”—rather than to retributive aims.

The opinion then did the doctrinal work necessary post-Esteras: it reaffirmed that seriousness of violation conduct remains relevant, not as a proxy for retribution, but as a measure of the gravity of the defendant’s breach of the court’s trust and as evidence bearing on forward-looking statutory goals. Put differently, the “seriousness” of what the defendant did while supervised is not being used to “punish that offense” as though it were a new conviction; it is being used to decide (a) whether the defendant can be trusted in the community, and (b) what sanction is necessary to prevent future harm.

2. Statutory grounding: § 3583(e) and the subset of § 3553(a) factors

The panel emphasized that revocation sentencing proceeds under 18 U.S.C. § 3583(e), which incorporates a subset of § 3553(a) factors—importantly including: the defendant’s history and characteristics (§ 3553(a)(1)), deterrence (§ 3553(a)(2)(B)), and protection of the public (§ 3553(a)(2)(C)). By tying the district court’s reasoning to those enumerated considerations, the court avoided the Esteras problem (retribution) and situated its affirmance in textually authorized purposes.

3. Substantive reasonableness: why the upward sentence survived

On substantive reasonableness, the panel leaned on deference: the question is not whether an appellate court would weigh factors differently, but whether the district court’s selection was outside the range of reasonable outcomes. Here, the panel found the 30-month sentence justified because:

• The fraud scheme and deception (including year-long faked drug tests) showed an unusually profound breach of supervisory trust.
• The need to protect the public was concrete and individualized: incapacitation was “especially important” to protect R.A., who remained vulnerable and continued to believe the kidnapping narrative.
• Williams had previously received a below-Guidelines sentence for the underlying drug offense—leniency reflecting trust—making the later breach a reasonable basis for an upward variance at revocation.

4. The no-contact condition: public protection, tailoring, and constitutional avoidance

The panel sustained the condition barring contact with S.H. on two complementary public-protection grounds: (1) S.H. was found to be a “coequal” participant who helped perpetuate the fraud, making contact a risk factor for recidivist collaboration; and (2) Williams threatened to kill S.H., making the restriction protective of her safety and a means of preventing intimidation or violence.

Importantly, the panel also treated the condition as less than an absolute ban: Williams could seek permission from his probation officer (Shultz) and could later seek modification under § 3583(e)(2) (Arnold), including if he married S.H. or circumstances changed. That framing does double duty: it supports the “no greater deprivation than necessary” requirement and also reduces the likelihood of a direct collision with the asserted right to marry.

C. Impact

1. A post-Esteras roadmap for revocation sentencing in the Sixth Circuit

The decision’s most significant contribution is its explicit reassurance that district courts may continue to evaluate the seriousness of violation conduct—so long as the articulated purpose is forward-looking (deterrence/public protection) and/or tied to the defendant’s breach of supervisory trust, rather than retribution. In practice, Williams supplies district judges with a vocabulary and structure for explaining upward revocation sentences without straying into prohibited rationale: “breach of trust,” “reintegration relationship,” “deterrence,” and “protecting the public.”

2. Strengthening the evidentiary link between “seriousness” and permissible factors

The opinion illustrates how concrete facts (multi-year fraud, deception of probation, repeated drug use hidden by synthetic compliance) can be used to justify both: (a) the magnitude of incapacitation needed to prevent future crimes, and (b) an assessment that ordinary supervisory tools are unlikely to work because the supervision relationship has been systematically manipulated. Future litigants should expect courts to cite Williams when arguing that “seriousness” is relevant as evidence of risk and untrustworthiness, not as a backdoor for punishment.

3. No-contact conditions with intimate partners: reinforced acceptance with tailoring mechanisms

On special conditions, Williams reinforces that no-contact conditions involving romantic partners are most defensible where the record shows: partner-facilitated criminality and/or threats of violence, and where the condition is implemented with “off-ramps” (permission and later modification). The decision may encourage district courts to draft such conditions with explicit permission/modification pathways to blunt constitutional challenges.

IV. Complex Concepts Simplified

• Supervised release & revocation: supervised release is a post-prison monitoring period. If the defendant violates conditions, the court can “revoke” it and impose prison time under 18 U.S.C. § 3583(e).
• Procedural vs substantive sentencing error: “procedural” concerns how the court sentenced (e.g., relying on an impermissible factor); “substantive” concerns whether the length/type of sentence is unreasonable given permissible factors. The distinction matters for standards of review.
• Plain error: a difficult-to-meet appellate standard requiring a clear/obvious error that affected substantial rights and the fairness/integrity of proceedings.
• “Retribution” vs “breach of trust”: retribution is backward-looking punishment because the defendant deserves it. “Breach of trust” is the idea that supervision depends on honesty and compliance; violating conditions breaks that trust and signals future risk—justifying forward-looking sanctions.
• Special conditions of supervised release: tailored rules beyond standard conditions. They must relate to statutory sentencing factors, be no more liberty-restrictive than necessary, and align with policy statements; if they implicate constitutional rights, courts demand a stronger fit to rehabilitation and public safety.

V. Conclusion

United States v. Terrell Lamar Williams clarifies two key points for Sixth Circuit revocation practice. First, even after the retribution limitation recognized through Esteras v. United States, district courts may consider the seriousness of violation conduct when it is used to assess deterrence, protection of the public, and—critically—the gravity of the defendant’s breach of the court’s trust. Second, courts may impose no-contact conditions involving romantic partners, even in the shadow of marriage-related constitutional arguments, where the record shows partner-facilitated wrongdoing and threats of violence and where the condition remains reasonably tailored through permission and modification mechanisms.