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

1. Introduction

In United States v. Jonathan Young (11th Cir. Jan. 12, 2026) (unpublished), the Eleventh Circuit reviewed two related outcomes arising from a single incident: (1) Jonathan Young’s jury conviction for being a felon in possession of ammunition under 18 U.S.C. § 922(g)(1); and (2) the district court’s decision to revoke Young’s supervised release in his older case and impose a 60-month consecutive revocation sentence.

The case stemmed from a late-night tow-truck repossession attempt. Video footage and witness testimony placed Young at the scene; shell casings were recovered; a gunshot-detection system registered shots; and the government introduced a jail call in which Young appeared to discuss whether police found shell casings and how he was identified “in the dark.”

The consolidated proceeding below is central to the appellate decision. Although the district court held Young’s sentencing for the new § 922(g)(1) conviction and the supervised-release revocation hearing on the same date, it gave extensive attention to the new-case sentence and only a brief, conclusory treatment to revocation—without addressing alleged violations or providing the procedural protections mandated by Federal Rule of Criminal Procedure 32.1.

Key issues on appeal were: (a) whether the evidence was sufficient to prove knowing possession of ammunition for the § 922(g)(1) conviction; and (b) whether the supervised-release revocation and 60-month revocation sentence complied with Rule 32.1 and federal sentencing procedure.

2. Summary of the Opinion

Conviction affirmed: The court held the trial evidence was sufficient for a rational jury to find that Young knowingly possessed ammunition.
Revocation vacated: The court held the district court plainly erred by failing to conduct a proper Rule 32.1(b)(2) revocation hearing (or obtain a waiver).
Revocation sentence vacated: The court held 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 record for appellate review.
Remand: The Eleventh Circuit remanded for a proper revocation hearing (or waiver) and resentencing on revocation.

3. Analysis

3.1 Precedents Cited

Sufficiency of the evidence framework

United States v. Doak, 47 F.4th 1340 (11th Cir. 2022)
The court relied on Doak for the standard of review: sufficiency challenges are reviewed de novo, with evidence viewed in the light most favorable to the government and with all reasonable inferences drawn in its favor.
United States v. Louis, 146 F.4th 1328 (11th Cir. 2025)
Cited twice for complementary propositions: (1) the “light most favorable to the prosecution” recitation of facts in sufficiency review; and (2) the articulation that evidence is insufficient “only if no reasonable trier of fact could find guilt beyond a reasonable doubt.”
Rehaif v. United States, 588 U.S. 225 (2019)
The court invoked Rehaif for the elements of § 922(g): the government must prove the defendant knowingly possessed ammunition and knew of his prohibited status. Here, status was undisputed; the live question was knowing possession.
United States v. Beach, 80 F.4th 1245 (11th Cir. 2023)
Beach supported the court’s rejection of Young’s “missing evidence” arguments (no gun recovered, no DNA testing, imperfect scene security). The panel emphasized that the absence of certain evidence does not undermine a conviction when other direct or circumstantial evidence suffices; appellate review does not reweigh evidence.
United States v. Farley, 607 F.3d 1294 (11th Cir. 2010)
The court used Farley to underscore that where there is a “reasonable basis in the record” for the verdict, the conviction must be sustained.

Revocation procedure, due process, and plain-error review

United States v. Owens, 96 F.4th 1316 (11th Cir. 2024)
Owens supplied the plain-error framework because Young did not object below on the Rule 32.1 ground. Under this framework, Young had to show a plain error affecting substantial rights.
United States v. Clotaire, 963 F.3d 1288 (11th Cir. 2020)
Clotaire was cited for the final discretionary step of plain error review: even when plain error is shown, appellate correction is reserved for errors that seriously affect the fairness, integrity, or public reputation of judicial proceedings.
United States v. Frazier, 26 F.3d 110 (11th Cir. 1994)
Frazier anchored the proposition that Rule 32.1 incorporates “minimal due process” protections for revocation proceedings—protections the district court failed to provide when it announced revocation in conclusory terms without litigating alleged violations or allowing a meaningful defense response.

Procedural reasonableness and Guidelines calculation

Gall v. United States, 552 U.S. 38 (2007)
The panel treated Gall as the governing authority for procedural reasonableness. It emphasized Gall’s rule that failing to calculate (or improperly calculating) the Guidelines range is significant procedural error, and that appellate review requires a record sufficient for “meaningful” evaluation.

3.2 Legal Reasoning

A. Why the § 922(g)(1) conviction stood

The court’s sufficiency analysis was straightforward: the jury had multiple mutually reinforcing evidentiary strands. The tow-truck security video depicted the encounter and captured audio consistent with two gunshots. The driver identified Young shortly after the incident via a photo lineup. Police recovered two shell casings from the scene and a “ShotSpotter” system detected two gunshots at a time and location consistent with the incident. Finally, the jail call supplied consciousness-of-guilt-type evidence: Young asked whether police found “poopins” or “doodles” and questioned how the driver “pointed” him out “in the dark,” with an officer testifying the terms appeared to refer to shell casings.

Against this, Young offered “missing evidence” and “alternative explanation” points (no gun recovered, no DNA testing, high-crime area). The panel treated these as invitations to reweigh credibility and competing inferences, which sufficiency review forbids. Under Doak, Louis, Beach, and Farley, the question was only whether a rational jury could find knowing possession beyond a reasonable doubt—not whether the government’s investigation was ideal.

B. Why revocation was vacated under Rule 32.1(b)(2)

The revocation portion of the hearing consisted of a brief announcement that the court had “carefully considered” the parties’ statements and the violation report, found Young in violation, revoked supervised release, and imposed 60 months. The Eleventh Circuit held this did not satisfy Rule 32.1(b)(2), which requires a revocation hearing within a reasonable time and affords the defendant key protections, including disclosure of the evidence, the opportunity to present evidence, and the right to make a statement and present mitigation.

The failure was particularly stark because the probation petition alleged fourteen violations, including several unrelated to the new conviction (e.g., alleged battery of a detainee, drug-testing violations, travel violations, alleged dishonesty to probation, and employment issues). Yet the district court did not address specific allegations, identify supporting evidence, or provide Young a genuine opportunity to contest the accusations or offer mitigation.

Even under plain-error review (Owens and Clotaire), the panel found the mistake plain and sufficiently serious to require vacatur. The remedy was also carefully tailored: on remand the district court must either (1) hold a Rule 32.1-compliant hearing or (2) obtain a waiver from Young.

C. Why the 60-month revocation sentence was procedurally unreasonable

The district court stated that “a sentence within the guideline range” was appropriate and then imposed 60 months. But neither the court nor probation identified the applicable revocation Guidelines range or explained how the range was computed. Under Gall v. United States, failing to calculate or to create an on-the-record basis for the Guidelines range is significant procedural error.

The Eleventh Circuit’s emphasis was not merely formal. Guidelines calculations in revocation proceedings can turn on: the violation grade, the defendant’s criminal history category, whether violations are proven/admitted, and statutory maximums. Without an articulated calculation, an appellate court cannot evaluate whether the sentence was anchored to the correct advisory framework or whether the “guideline range” label was accurate.

3.3 Impact

Revocation cannot be an afterthought—even in consolidated hearings: District courts may calendar a revocation hearing alongside sentencing in a new case, but they must still provide the discrete Rule 32.1(b)(2) protections (or secure a valid waiver).
Multiple alleged violations increase the need for procedural clarity: Where petitions allege numerous violations (some unrelated to a new conviction), the court must clarify which violations are being adjudicated, what evidence supports them, and what the defendant’s response is. A later “corrected judgment” identifying revocation “based on” the new conviction does not substitute for the required hearing process.
On-the-record Guidelines calculation is required for meaningful review: Even if the ultimate sentence could be justified, the record must show the Guidelines range and how it was derived, consistent with Gall. This decision thus incentivizes district courts to articulate revocation ranges and reasoning to avoid automatic procedural reversals.
Unpublished but practically important: Although designated “NOT FOR PUBLICATION,” the opinion illustrates a recurring operational rule: perfunctory revocation pronouncements risk vacatur, especially where the transcript reflects no Rule 32.1 compliance and no Guidelines calculation.

4. Complex Concepts Simplified

§ 922(g)(1) (felon-in-possession) and “ammunition”: Federal law forbids a convicted felon from possessing firearms or ammunition. “Possession” can be proven by direct evidence (e.g., video) or circumstantial evidence (e.g., shell casings tied to the defendant’s conduct).
Rehaif knowledge requirement: After Rehaif v. United States, the government must prove the defendant knew he belonged to a prohibited category (e.g., knew he was a felon) at the time of possession. In this case, the parties did not dispute that element.
Supervised release and “revocation”: Supervised release is a post-prison monitoring term with conditions. If the defendant violates conditions, the court may revoke supervised release and impose additional prison time.
Rule 32.1(b)(2) revocation hearing rights: Rule 32.1 requires basic procedural fairness: disclosure of evidence, a chance to contest allegations and present evidence, and an opportunity to speak and offer mitigation before the court decides revocation and punishment.
Plain error review: If a defendant did not object in the district court, the appellate court applies a stricter test. The defendant must show an obvious (plain) error that likely mattered (affected substantial rights), and the appellate court must decide correction is necessary to protect the integrity of the proceedings.
Procedural reasonableness and Guidelines calculation: A sentence can be reversed not because it is “too long,” but because the process was defective—such as failing to calculate and state the applicable advisory Guidelines range, which is a baseline for sentencing analysis and appellate review.

5. Conclusion

The Eleventh Circuit’s disposition in United States v. Jonathan Young draws a clear procedural boundary: strong evidence can sustain a § 922(g)(1) conviction even where certain investigative steps were not taken, but supervised-release revocation and revocation sentencing must comply with Rule 32.1 and federal sentencing procedure. A revocation “hearing” that consists of a conclusory announcement—without disclosure of evidence, an opportunity to respond, or mitigation—cannot stand, and a revocation sentence imposed without an articulated Guidelines calculation is procedurally unreasonable under Gall v. United States.