United States v. Collins: Early-Termination Denials Cannot Rest on a “Fifty-Percent” Custom Without an Individualized § 3553(a) Analysis

1. Introduction

In United States v. Guy Collins (Sixth Cir. Apr. 1, 2026), the Sixth Circuit addressed a recurring practice in supervised-release administration: a district court’s “custom” of not considering early-termination motions until the defendant has completed at least half of the supervised-release term. Guy Collins—serving an eight-year term of supervised release after a crack-cocaine conspiracy conviction—filed three motions for early termination under 18 U.S.C. § 3583(e)(1). The district court denied the first despite praising Collins’s exceptional rehabilitation and stating that further supervision did not appear necessary for deterrence or public protection; denied the second based almost entirely on its “fifty-percent” custom; and denied the third while attempting to justify continued supervision on deterrence/public-protection grounds.

The key issues on appeal were whether the district court (i) may deny early termination as “premature” based on a blanket percentage-of-term-served practice and (ii) must explain how the time served relates to the statutorily relevant § 3553(a) factors, especially where the court’s reasoning conflicts across orders.

2. Summary of the Opinion

The Sixth Circuit held that the district court abused its discretion in denying both the second and third motions. It vacated the denials and remanded.

  • Second Order: The district court’s one-paragraph denial—stating the motion was “premature” because Collins had not completed half of supervision—failed to show consideration of the relevant § 3553(a) factors required by § 3583(e)(1).
  • Third Order: The district court’s later attempt to “backfill” reasoning failed because it contradicted the first order’s statement that supervision was not needed for deterrence/public protection and did not explain the change in position.

The Sixth Circuit emphasized that courts may not add a de facto time requirement beyond the statute’s one-year eligibility threshold unless the decision is grounded in an individualized statutory-factor analysis.

3. Analysis

3.1. Precedents Cited

Appellate standard of review and explanation requirement

  • United States v. Hale, 127 F.4th 638 (6th Cir. 2025) and United States v. Tavarez, 141 F.4th 750 (6th Cir. 2025): The panel reaffirmed abuse-of-discretion review for early-termination decisions and relied on Tavarez for the proposition that denials must reflect a reasoned decisionmaking process tied to the relevant statutory considerations.
  • United States v. Carter, 463 F.3d 526 (6th Cir. 2006): Quoted (via Tavarez) for the baseline definition of abuse of discretion, including use of an erroneous legal standard.
  • United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020): Cited (again via Tavarez) for the “record as a whole” principle—appellate confidence requires that the district court considered the parties’ arguments and had a reasoned basis for its decision.

Statutory-factor limits under § 3583(e)(1)

  • Esteras v. United States, 606 U.S. 185 (2025): Central to the panel’s analysis. Esteras holds that because § 3553(a)(2)(A) is omitted from § 3583(e), district courts cannot consider retribution—i.e., they cannot rely on “the need to exact retribution for the defendant’s underlying crime”—when deciding early termination. This materially constrained the district court’s ability to justify denial by invoking the seriousness of the original offense.

Sixth Circuit treatment of categorical practices and missing-factor analysis

  • United States v. Zai, No. 22-3371, 2022 WL 17832201 (6th Cir. Dec. 21, 2022): Used to underscore that an order denying early termination is deficient when it provides no indication that the court considered the relevant § 3553(a) factors.
  • United States v. Evans, No. 25-5118, 2025 WL 2486607 (6th Cir. Aug. 26, 2025): Closely analogous: the district court denied early termination because it did not consider defendant-filed motions as a matter of practice; the Sixth Circuit required remand because the order did not mention the required § 3553(a) factors. Collins extends that logic to a “fifty-percent” custom that effectively screens out consideration.

Persuasive authority rejecting categorical time-remaining policies

  • United States v. Lowe, 632 F.3d 996 (7th Cir. 2011): The Seventh Circuit rejected a policy of refusing early termination unless the defendant had 12 months or less remaining, calling it arbitrary and contrary to § 3583(e)(1). The Sixth Circuit found Lowe persuasive support for rejecting a blanket time-served threshold untethered to statutory factors.

Analogy to compassionate release and individualized § 3553(a) analysis

  • United States v. Bailey, No. 20-5951, 2021 WL 3631341 (6th Cir. Aug. 17, 2021): Invoked for the principle that time-served “presumptions” are problematic because sentence modifications require individualized application of § 3553(a). The panel used this analogy to reinforce that a “fifty-percent” presumption in supervised release would likewise contravene individualized consideration.

Time-served as potentially relevant—but only if explicitly linked to § 3553(a)

  • United States v. Butler, No. 22-5877, 2023 WL 6552878 (6th Cir. June 14, 2023), abrogated on other grounds by United States v. Hale, 127 F.4th 638 (6th Cir. 2025): The opinion acknowledges that a “short amount of time” served may be relevant to factors like deterrence and disparity, but emphasizes that courts must articulate the connection; the proportion served is not itself a statutory factor.
  • United States v. Tavarez, 141 F.4th 750 (6th Cir. 2025): Quoted for the proposition that the mere fact a defendant has not served half of supervision does not, standing alone, concern any relevant § 3553(a) factor.

Other cited authorities (supporting context)

  • United States v. Harris, No. 21-5805, 2023 WL 4030070 (6th Cir. June 15, 2023), abrogated on other grounds by United States v. Tavarez, 141 F.4th 750 (6th Cir. 2025): Cited for the proposition that district courts remain empowered to terminate supervised release after one year even where the original statute contemplated lengthy minimum terms.
  • United States v. Gowder, No. 20-6117, 2021 WL 1328601 (6th Cir. Mar. 1, 2021) and United States v. DeLong, Nos. 21-3255/3429/3509, 2022 WL 816957 (6th Cir. Jan. 24, 2022): Cited to support appellate jurisdiction over the denial of a Rule 37 motion during a pending appeal (relevant to the third motion’s procedural posture).

3.2. Legal Reasoning

(A) The core doctrinal holding: no blanket percentage threshold

The Sixth Circuit’s central rule is straightforward: a district court cannot employ a blanket “custom” requiring completion of a fixed proportion of supervised release (here, 50%) without conducting an individualized assessment under the relevant § 3553(a) factors incorporated by § 3583(e)(1). A “prematurity” denial that operates as a categorical screen is inconsistent with the statute, which allows termination “at any time after the expiration of one year” if warranted by the defendant’s conduct and the interest of justice.

(B) The Second Order failed because it did not show statutory-factor consideration

The Second Order was effectively a one-factor decision: Collins had not yet reached the court’s customary “halfway point.” The Sixth Circuit deemed this an abuse of discretion because the order did not explain how the elapsed portion of the term related to deterrence, public protection, rehabilitation, disparities, guidelines/policy statements, or other relevant factors.

(C) The First Order could not “save” the Second Order

The panel rejected the idea that earlier reasoning could be imputed to the Second Order. Critically, the First Order contained a finding that further supervision did not appear necessary for deterrence or public protection. Thus, the district court could not logically deny the second motion on those grounds without explanation.

The First Order’s references to “seriousness” of the offense and “extensive criminal history” also did not justify denial in this context, because (i) those considerations were not linked to a permissible § 3583(e) purpose and (ii) under Esteras v. United States the court cannot deny early termination based on retribution.

(D) The Third Order failed because it contradicted the court’s earlier reasoning and still lacked a coherent statutory link

The Third Order attempted to reframe the fifty-percent custom as flexible and individualized, and asserted that continued supervision was needed for deterrence and public protection. The Sixth Circuit refused to credit this because it directly conflicted with the First Order’s express statement that such supervision did not appear necessary—and the district court never explained why it changed its mind.

Additionally, the panel clarified an important nuance: even if the amount of time served can sometimes inform permissible factors (e.g., deterrence), the court must explicitly draw that connection for the particular defendant; time served “standing alone” is not a relevant consideration. Congress set the temporal eligibility threshold (one year), and courts may not effectively amend that threshold by custom.

(E) Procedural jurisdiction: Rule 37 and appeal

Because the third motion was filed while the appeal of the second denial was pending, the district court’s authority was governed by Federal Rule of Criminal Procedure 37. Rule 37 permits denial of the motion despite the pending appeal, making the Third Order reviewable as a final order under 28 U.S.C. § 1291.

3.3. Impact

  • Direct constraint on district “customs” and informal policies: In the Sixth Circuit, courts may not deny early termination simply because a defendant has not served a customary fraction (e.g., half) of supervision. Practices common within a district (as defense counsel asserted here) now carry significant appellate risk if they operate categorically.
  • Stronger explanation obligations: Denials must show that the court actually engaged the relevant § 3553(a) factors and the parties’ arguments. “Premature” is not self-explanatory unless tied to a statutory factor and the defendant’s individualized circumstances.
  • Reinforcement of Esteras in supervised-release administration: Courts must be careful not to smuggle retribution into § 3583(e)(1) decisions through references to offense seriousness untethered to permissible aims.
  • Litigation posture and record-building: Defendants and the government will likely focus more on developing a record that links conduct-on-supervision to specific statutory purposes (deterrence, public protection, treatment, disparity) and on highlighting inconsistencies across orders.

4. Complex Concepts Simplified

  • Early termination of supervised release (18 U.S.C. § 3583(e)(1)): A judge may end supervised release early after the person has completed at least one year, but only after considering specified sentencing factors and concluding early termination is warranted by the person’s conduct and the interest of justice.
  • § 3553(a) factors: The sentencing considerations Congress listed—such as deterrence, protecting the public, rehabilitation/treatment needs, guideline policy statements, and avoiding unwarranted disparities. Not all factors apply in all post-sentencing settings.
  • Retribution excluded under § 3583(e): Under Esteras v. United States, judges deciding early termination cannot base the decision on punishment for punishment’s sake (i.e., “you deserve to serve the full term because the crime was serious”). They must stick to the factors Congress incorporated (like deterrence, public protection, treatment).
  • “Individualized assessment”: The court must evaluate the specific defendant’s record and circumstances; a shortcut rule (like “we won’t consider it until 50%”) is the opposite of individualized decisionmaking unless the court explains, for that defendant, how time served connects to the statutory factors.
  • Rule 37 indicative ruling procedure: When an appeal is pending, the district court generally cannot grant certain relief—but it may deny the motion, defer it, or state it would grant it if the appellate court remands. Here, the district court denied, allowing appellate review.

5. Conclusion

United States v. Collins establishes (and publishes) a clear Sixth Circuit rule: district courts may not deny supervised-release early termination based on a categorical “fifty-percent” custom or similar time-served threshold without an individualized analysis grounded in the relevant § 3553(a) factors. The decision also underscores that courts cannot justify denial through retributive reasoning barred by Esteras v. United States, and that courts must address inconsistencies in their own reasoning across successive orders.

On remand, the district court must do what the statute requires: explain, in Collins’s case, how the relevant § 3553(a) factors bear on whether early termination is warranted by his conduct and the interest of justice—without defaulting to a customary halfway rule.