Jonathan Mendez-Escobar v. United States

Federal courts frequently impose terms of supervised release on defendants who are concededly deportable and will be removed from the United States upon completion of their custodial sentences. The Sentencing Guidelines instruct that such terms ordinarily should not be imposed absent a case-specific justification, yet district courts often impose supervised release without explanation. On appeal, courts routinely affirm these sentences under plain-error review, even where the record contains no individualized reasoning. The result is that supervised-release terms are imposed in a manner that evades meaningful appellate scrutiny and undermines this Court’s requirement of reasoned sentencing. The questions presented are:

1. May a sentencing court impose supervised release on a deportable defendant without providing a case-specific justification?

2. May a court of appeals affirm such a sentence under plain-error review despite the absence of any individualized explanation?