Tenth Circuit Bars Collateral Attacks on State Convictions in Revocation Sentencing: United States v. Beck (2025)

1. Introduction

United States v. Beck, No. 24-7036, decided by the U.S. Court of Appeals for the Tenth Circuit on 1 August 2025, addresses the scope of issues that may be raised during an appeal from a supervised-release revocation sentence. The defendant, Joses Ric-E Beck, challenged the substantive reasonableness of a two-year sentence imposed after the district court revoked his supervised release. Beck argued chiefly that the district court erred by:

• Considering his failure to comply with the Sex Offender Registration and Notification Act (SORNA) because, he claimed, the underlying 2008 Oklahoma sex-offense conviction was jurisdictionally void under McGirt v. Oklahoma.
• Failing to give sufficient weight to his mental-health history and limited life skills.
• Misapplying the 18 U.S.C. § 3553(a) factors.

The Tenth Circuit rejected each contention, thereby clarifying that a defendant may not collaterally attack an underlying state conviction during an appeal from a revocation sentence and confirming the deferential presumption of reasonableness afforded to within-Guidelines revocation sentences.

2. Summary of the Judgment

The panel (Hartz, Eid, and Federico, JJ.) affirmed the 24-month revocation sentence. Key holdings include:

1. The challenge to the validity of Beck’s 2008 state conviction, raised to negate SORNA non-compliance, is an impermissible collateral attack in this procedural posture.
2. McGirt does not retroactively invalidate final state convictions; therefore, Beck remained obliged to register under SORNA.
3. The district court acted within its discretion when it weighed Beck’s mental-health history and life circumstances yet imposed a sentence at the top of the 18-to-24-month Guidelines range.
4. A within-Guidelines revocation sentence is presumed substantively reasonable; Beck failed to rebut that presumption.

3. Analysis

3.1 Precedents Cited

• United States v. Williams, 106 F.4th 1040 (10th Cir. 2024) – standard of review (abuse of discretion) for revocation decisions.
• United States v. Rausch, 638 F.3d 1296 (10th Cir. 2011) – reasonableness review framework for revocation sentences.
• United States v. Friedman, 554 F.3d 1301 (10th Cir. 2009) and Alapizco-Valenzuela, 546 F.3d 1208 (10th Cir. 2008) – articulation of substantive-reasonableness standard.
• United States v. McBride, 633 F.3d 1229 (10th Cir. 2011) – presumption of reasonableness for within-Guidelines revocation sentences.
• United States v. Palomino-Garcia, 190 F. App’x 648 (10th Cir. 2006) and United States v. Delacruz-Soto, 414 F.3d 1158 (10th Cir. 2005) – impermissibility of collateral attacks on prior convictions in sentencing proceedings.
• McGirt v. Oklahoma, 591 U.S. 894 (2020) – Oklahoma’s lack of criminal jurisdiction over major crimes committed by tribal members in Indian Country.
• Pacheco v. Habti, 62 F.4th 1233 (10th Cir. 2023) – holding that McGirt is not retroactive to cases already final.
• United States v. Diaz, 967 F.3d 107 (2d Cir. 2020) – SORNA does not authorize federal courts to revisit the validity of predicate state convictions.

These authorities collectively underscored two propositions: (1) revocation sentences within the advisory range demand deference, and (2) sentencing courts (and reviewing courts) may not reopen or undermine prior convictions, absent explicit statutory authorization.

3.2 Legal Reasoning

The court proceeded through the following analytical steps:

1. Standard of Review. Revocation and sentencing decisions are reviewed for abuse of discretion; substantive reasonableness is gauged against § 3553(a).
2. Collateral-Attack Doctrine. Beck’s attempt to use the revocation appeal to challenge the jurisdictional validity of his 2008 conviction violates long-standing precedent that sentencing proceedings are not forums for undoing final convictions. The panel characterized the argument as an “impermissible collateral attack.”
3. Retroactivity of McGirt. Even if collateral review were procedurally proper, Pacheco forecloses retroactive application of McGirt to final state judgments, leaving the conviction (and accompanying SORNA duties) intact.
4. Weight of § 3553(a) Factors. The district court explicitly addressed the nature and circumstances of the violations, deterrence, public protection, restitution, and Beck’s personal characteristics. The Tenth Circuit reiterated that appellate courts do not reweigh these factors so long as the sentencing court’s balancing is not manifestly unreasonable.
5. Guidelines Presumption. Because the 24-month sentence lay within the 18-24-month Chapter 7 range, it attracted a presumption of reasonableness. Beck’s personal history did not suffice to rebut it.

3.3 Impact of the Decision

The judgment’s ramifications extend beyond Beck:

• Finality of State Convictions. The decision reinforces that defendants under federal supervision cannot parlay recent jurisdictional rulings—such as McGirt—into collateral challenges during revocation or resentencing proceedings.
• SORNA Enforcement. Probation offices and district courts may freely rely on state convictions, even when defendants assert later-developed jurisdictional theories, to measure SORNA compliance and to bolster revocation decisions.
• Guidelines Deference Post-Revocation. The Ninth and Eleventh Circuits already apply a similar presumption of reasonableness; Beck confirms that the Tenth Circuit will continue to grant substantial leeway to within-range revocation sentences.
• Mental-Health Mitigation. While mental-health histories remain relevant, the opinion signals that repeated non-compliance may outweigh mitigating factors when public safety and deterrence are at stake.
• Strategic Litigation Choices. Defendants with potential jurisdictional arguments must pursue appropriate state post-conviction or federal habeas avenues before supervised release triggers new federal obligations.

4. Complex Concepts Simplified

• Supervised Release: A period of court-ordered community supervision following imprisonment, during which the defendant must follow specific conditions (similar to probation but attached to a federal sentence).
• SORNA: A federal statute requiring individuals convicted of qualifying sex offenses to register and keep registration current; non-compliance may itself be a federal crime.
• Collateral Attack: An attempt to undermine a conviction in a proceeding other than a direct appeal of that conviction (e.g., habeas corpus, or here, a revocation appeal). Generally disfavored unless expressly permitted by statute.
• Abuse of Discretion Standard: An appellate court will overturn a decision only if it is arbitrary, capricious, or manifestly unreasonable.
• Presumption of Reasonableness: A doctrine whereby a sentence within the correctly calculated advisory Guidelines range is considered reasonable unless the defendant shows otherwise.
• Retroactivity: The principle determining whether a new legal rule applies to cases that have already become final. Beck reaffirms that McGirt is not retroactive to final convictions within the Tenth Circuit.

5. Conclusion

United States v. Beck crystallizes an important procedural boundary: a supervised-release revocation proceeding cannot serve as a back-door vehicle for contesting the validity of a predicate state conviction, even where intervening Supreme Court jurisprudence hints at a jurisdictional defect. The Tenth Circuit’s decision safeguards the finality of state judgments, fortifies SORNA’s enforceability, and underscores the deferential review accorded to within-Guidelines revocation sentences. Practitioners should note that mitigation arguments grounded in mental health and life skills, while relevant, face an uphill battle where the record reflects sustained disregard for supervised-release conditions. In the broader doctrinal landscape, Beck articulates a clear rule: Absent statutory authorization, collateral attacks belong in dedicated post-conviction forums, not in appeals of revocation sentences.