Revocation Requires a Real Rule 32.1 Hearing and an On-the-Record Guidelines Calculation

I. Introduction

United States v. Jonathan Young (11th Cir. Jan. 12, 2026) addresses two procedurally distinct tracks that often collide in federal practice: (1) sentencing on a new criminal conviction, and (2) revocation of supervised release from an earlier case. Jonathan Young, previously convicted in federal court and serving supervised release, was tried for conduct arising from a late-night tow-truck repossession incident. A jury convicted him only of possessing ammunition as a felon under 18 U.S.C. § 922(g)(1). Separately, based largely on that new case, the district court revoked his supervised release and imposed a 60-month consecutive revocation sentence.

On appeal, Young raised three issues: (i) whether evidence was sufficient to prove knowing possession of ammunition, (ii) whether the court followed the procedural requirements for revoking supervised release, and (iii) whether the revocation sentence was procedurally reasonable. The Eleventh Circuit affirmed the § 922(g)(1) conviction, but vacated the revocation decision and revocation sentence, remanding for a proper Rule 32.1 process and resentencing with an identifiable Guidelines calculation.

II. Summary of the Opinion

Conviction affirmed: The court held sufficient evidence supported the jury’s finding that Young knowingly possessed ammunition (shell casings tied to the incident, corroborated by video/audio, eyewitness identification, gunshot-detection data, and a jail call).
Revocation vacated: The district court plainly erred by not conducting a meaningful revocation hearing under Federal Rule of Criminal Procedure 32.1(b)(2) (no disclosure of evidence, no chance to respond or present mitigation).
Revocation sentence vacated: The district court committed procedural error by failing to calculate (or at least identify and explain) the applicable Guidelines range for the revocation sentence, leaving no “meaningful” appellate record.
Remand instructions: The district court must hold a proper revocation hearing or obtain a waiver, and must resentence with a record that includes the Guidelines range calculation.

III. Analysis

A. Precedents Cited

1. Sufficiency of the Evidence Framework

United States v. Doak, 47 F.4th 1340 (11th Cir. 2022)
The court used Doak for the standard of review: sufficiency is reviewed de novo, with all reasonable inferences drawn in favor of the prosecution. This set the lens through which the panel evaluated the video, identification, shell casings, and jail call.
United States v. Louis, 146 F.4th 1328 (11th Cir. 2025)
Louis served two roles: (i) it supported reciting facts “in the light most favorable to the prosecution,” and (ii) it provided the articulation that evidence is insufficient only if “no reasonable trier of fact could find guilt beyond a reasonable doubt.” This reinforced the court’s refusal to reweigh competing inferences about missing forensic testing and the unrecovered firearm.
United States v. Beach, 80 F.4th 1245 (11th Cir. 2023)
Beach undercut Young’s “missing evidence” attack. The panel emphasized that the absence of certain proof (DNA testing, recovered gun/bullets, scene security) does not defeat a conviction where other direct/circumstantial evidence supports the verdict.
United States v. Farley, 607 F.3d 1294 (11th Cir. 2010)
Farley supplied the deferential endpoint: if there is a “reasonable basis in the record” for the verdict, the appellate court must sustain it. The panel used this to reject Young’s invitation to treat alternative explanations (high-crime area, “random shells”) as dispositive.

2. Elements of § 922(g) and Knowledge

Rehaif v. United States, 588 U.S. 225 (2019)
The panel cited Rehaif for the requirement that the government prove the defendant knowingly possessed ammunition (and, generally, knew of his prohibited status). Because Young’s felon status was undisputed, the case narrowed to whether the jury could find knowing possession of ammunition. The cited evidence (video/audio of shots, shell casings, and incriminating jail-call discussion about casings and identification) supplied that link.

3. Rule 32.1 Revocation Procedure and Plain-Error Review

United States v. Owens, 96 F.4th 1316 (11th Cir. 2024)
Owens anchored the panel’s use of plain-error review because Young did not object below to the Rule 32.1 deficiencies. This mattered because plain error requires showing an obvious mistake that affects substantial rights.
United States v. Clotaire, 963 F.3d 1288 (11th Cir. 2020)
Clotaire supplied the final discretionary step: even after plain error is shown, appellate correction is warranted only if the error seriously affects the fairness, integrity, or public reputation of judicial proceedings. The panel’s application reflects a view that “revocation in name only” is the type of structural procedural breakdown that undermines the proceeding’s legitimacy.
United States v. Frazier, 26 F.3d 110 (11th Cir. 1994)
The panel used Frazier to tie Rule 32.1 to “minimal due process” protections in revocation proceedings. This citation framed the district court’s failures (no evidence disclosure, no opportunity to present evidence, no mitigation statement) as not merely technical violations, but due-process deficiencies.

4. Procedural Reasonableness and Guidelines Calculation

Gall v. United States, 552 U.S. 38 (2007)
Gall provided the governing principle that failing to calculate (or improperly calculating) the Guidelines range is “significant procedural error.” The panel applied Gall to the revocation sentence because the district court declared 60 months was “within the guideline range,” but created no record of what range applied or how it was computed, preventing “meaningful” appellate review.

B. Legal Reasoning

1. Why the § 922(g)(1) Conviction Survived

The court treated the prosecution’s proof as a cumulative evidentiary chain: video/audio depicting the confrontation and shots, the tow-truck driver’s identification of Young, recovery of shell casings consistent with shots fired, ShotSpotter confirmation of two gunshots at a matching time and location, and a jail call interpreted as consciousness-of-guilt (inquiring about casings and questioning how the driver identified him “in the dark”). Under the Doak/Louis framework, the question was not whether alternative explanations were possible, but whether a reasonable jury could find knowing possession beyond a reasonable doubt.

The defense’s emphasis on investigative gaps (no gun recovered, no DNA testing, imperfect scene security) was treated as classic reweighing: arguments that may be put to a jury, but do not compel acquittal on appeal. Beach and Farley supplied the doctrinal basis to affirm despite missing forensic evidence.

2. Why Revocation Was Vacated: “Hearing in Name Only” Violates Rule 32.1

The opinion’s core procedural holding is that consolidation with sentencing on a new conviction does not excuse Rule 32.1’s distinct process. Rule 32.1(b)(2) requires, at the revocation hearing, disclosure of the evidence, an opportunity to present evidence, and a chance to make a statement and offer mitigation. Here, the probation petition alleged fourteen violations, yet the district court did not litigate any alleged violation on the record, did not identify the evidence, and did not give Young an opportunity to respond or mitigate. The court instead issued a brief, conclusory pronouncement revoking supervision and imposing a 60-month sentence.

Applying plain-error review under Owens and Clotaire, the panel found the violation obvious and substantial: revocation is a liberty deprivation that must satisfy at least “minimal due process” under Frazier. The remedy is a remand for a proper Rule 32.1 hearing or a valid waiver.

3. Why the Revocation Sentence Was Vacated: No Identifiable Guidelines Range

Independent of the hearing defect, the panel vacated the 60-month revocation sentence as procedurally unreasonable. Under Gall v. United States, the district court must calculate (or otherwise make clear) the applicable Guidelines range. The district court stated that 60 months was “within the guideline range,” but neither the court nor probation identified the range or explained its derivation. That left the Eleventh Circuit without a usable record to evaluate reasonableness, necessitating remand for resentencing with an articulated Guidelines calculation.

C. Impact

Revocation cannot be “assumed” from the new conviction: Even where a new conviction may ultimately support revocation, the defendant is still entitled to the Rule 32.1 process unless waived. Courts must treat revocation as a separate adjudicative step, not an administrative add-on to sentencing.
Record-building is mandatory: A conclusory statement that a term is “within the guideline range” is inadequate. The case signals that appellate courts will not infer the range or its calculation where the record is silent, especially for a lengthy consecutive revocation term.
Practical consequence for district courts: When combining sentencing and revocation, courts should (i) identify which violations are being pursued, (ii) summarize the evidence or the basis for findings, (iii) allow allocution and mitigation specific to revocation, and (iv) put the applicable revocation policy statement range on the record before imposing sentence.
For litigants: Defense counsel can use this opinion to demand a complete Rule 32.1 colloquy and to insist on an explicit Guidelines calculation. Prosecutors and probation must be prepared to present the evidentiary basis for the specific violations relied on.

IV. Complex Concepts Simplified

“Sufficiency of the evidence”: On appeal, the court does not decide whether it believes the defendant is guilty. It asks only whether a reasonable jury could find guilt beyond a reasonable doubt, viewing the evidence in the government’s favor.
“Knowing possession” (in § 922(g)(1)): The government must prove the defendant knowingly had ammunition (actual or constructive possession). Here, shell casings plus video/audio and incriminating statements supported an inference that Young fired a gun and therefore possessed ammunition.
“Plain error” review: If a defendant didn’t object in the district court, the appellate court corrects only clear errors that likely mattered to the outcome and seriously undermine fairness or integrity.
Rule 32.1 revocation hearing: A supervised-release revocation is not automatic; it requires a hearing with basic procedural rights: notice of the alleged violations, disclosure of evidence, a chance to contest allegations, present evidence, and argue mitigation.
“Procedural reasonableness” and Guidelines calculation: Before sentencing (including on revocation), the court must determine the applicable advisory range and create a record showing what it is and how it was reached, so an appellate court can review the sentence.

V. Conclusion

United States v. Jonathan Young draws a sharp procedural line: a supervised-release revocation cannot be handled as a perfunctory postscript to a new-case sentencing. Rule 32.1 requires a real hearing (or a waiver), and Gall v. United States requires an on-the-record Guidelines calculation sufficient for meaningful appellate review. While the conviction under § 922(g)(1) was affirmed on a robust evidentiary record, the revocation and its 60-month sentence were vacated because the district court’s process did not meet the minimum procedural and record-making demands that protect liberty and preserve appellate oversight.