United States v. Matta

Citations: 777 F.3d 116; 2015 U.S. App. LEXIS 1096; 2015 WL 304209Docket: No. 13-4078

Court: Court of Appeals for the Second Circuit; January 25, 2015; Federal Appellate Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

The appeal revolves around whether a sentencing court can delegate its authority to the United States Probation Department regarding a defendant's drug treatment requirements as a condition of supervised release. The District Court had imposed a condition that allowed the Probation Department to decide between inpatient and outpatient treatment for Luis Matta, who challenged this delegation among other sentencing issues. The appellate court found the delegation improper, vacated the special condition, and remanded the case for the District Court to determine the appropriate treatment type for Matta. The court rejected Matta’s additional challenges to his sentence, affirming all other aspects of the ruling. 

Matta had previously pleaded guilty to firearm possession, receiving a 36-month prison sentence followed by three years of supervised release. After his release in August 2012, he faced multiple violations, including assault and drug use, leading to the revocation of his supervised release in August 2013. Following this, he pleaded guilty to several charges related to his violations and discussed drug treatment options during sentencing. The District Court calculated Matta’s Sentencing Guidelines range as 8 to 14 months, which was not contested by the parties.

The court reviewed the events on August 31, 2013, which led to the dismissed charges against Matta, noting his violations began shortly after a less than six-month supervised release period, highlighted by a serious violent incident involving a woman that resulted in significant injury. Despite the dismissal of charges eight through ten, the context of violence and alcohol raised concerns about Matta's learning from the incidents. The District Court sentenced Matta to 24 months of imprisonment followed by 12 months of supervised release, requiring participation in a drug treatment program, with discretion left to the Probation Department to decide between inpatient or outpatient treatment.

Matta did not object to this special condition, leading to his appeal on the grounds that the District Court improperly delegated its sentencing authority. The court agreed that this delegation was impermissible and vacated that portion of the sentence, remanding it back to the District Court for a determination on the treatment type. While the Government argued for plain error review due to Matta's lack of objection, the court noted that he had insufficient opportunity to raise this issue prior to sentencing since the Presentence Report did not mention such delegation, and the District Court did not provide timely notice of it.

Matta's challenge to the District Court’s delegation of authority regarding special conditions of supervised release is addressed with leniency due to the nature of the alleged error being related solely to sentencing and Matta's lack of prior notice. The district court holds exclusive power to impose special conditions, such as participation in a substance abuse program, under 18 U.S.C. 3583 and U.S.S.G. 5D1.3. While minor details of supervised release can be delegated to probation officers, significant decisions affecting a defendant’s liberty cannot be. A special condition requiring a defendant to participate in a substance abuse intervention only at the probation officer's direction constitutes an impermissible delegation of judicial authority. Inpatient drug treatment, which confines the offender to a facility, is significantly more restrictive than outpatient treatment, which allows for home residence and employment. This distinction has been recognized by the Ninth and Tenth Circuits, which have ruled that district courts cannot delegate decisions regarding inpatient versus outpatient treatment due to the substantial liberty interests at stake. Any condition affecting such interests must be imposed by the district court with specific findings justifying its necessity. The District Court's delegation to the Probation Department regarding treatment options is deemed an impermissible delegation of sentencing authority. Consequently, that portion of the sentence is vacated, and the case is remanded for the District Court to properly impose treatment conditions as needed. Additionally, Matta contends that his sentence unlawfully exceeds the statutory maximum of 24 months due to the inclusion of four months in a residential reentry center as a special condition of supervised release.

Matta's argument against his sentence is rejected for two main reasons. First, under 18 U.S.C. § 3583(d), district courts are authorized to require defendants to reside in a community corrections facility as a condition of supervised release, which is permitted following incarceration. Since Matta's four-month residential reentry center term is a condition of supervised release, it is statutorily authorized. Second, 18 U.S.C. § 3583(e) defines the statutory maximum as applicable only to time spent in prison, clarifying that residential reentry centers are forms of community confinement, not imprisonment. The distinction between "imprisonment" and "community confinement" is emphasized, supporting the imposition of community confinement as a condition of supervised release, which serves a different purpose than the original sentence.

Regarding procedural and substantive reasonableness, Matta contests his 24-month imprisonment term. Procedural reasonableness examines whether the district court properly calculated the Guidelines range and considered relevant factors, while substantive reasonableness assesses the justification for the sentence against 18 U.S.C. § 3553(a). The court finds Matta's sentence to be neither procedurally nor substantively unreasonable. Matta's procedural claim, regarding the consideration of conduct related to dismissed charges from an incident, is reviewed for plain error since he did not raise the issue at sentencing. The court's reference to this incident was minimal and did not constitute error, as it was contextualized within broader considerations of Matta's behavior.

Matta's substantive challenge based on the length of his sentence exceeding the recommended Guidelines range of 8 to 14 months is also dismissed. The district court provided adequate reasoning aligned with § 3553(a) factors, and the imposed sentence is deemed within the permissible range of decisions. Ultimately, the court retains the discretion to modify sentences within statutory limits.

The court vacated and remanded the challenged condition of supervised release while affirming the remainder of the sentence. The document notes inconsistencies in naming the office responsible for federal probation across different districts, specifically referring to it as the "Probation Department" for the Eastern District of New York. The District Court's findings were based on an evidentiary hearing led by a magistrate judge, whose report and recommendations were adopted. The defendant, Matta, did not contest the third charge and did not challenge convictions on the first three charges on appeal. Both the Government and the Probation Department recommended a 14-month imprisonment term. Previous non-precedential cases from other circuits have suggested that delegating authority in similar contexts may be permissible, though they lacked extensive analysis on the specific issue at hand. Matta argued that placement in a residential reentry center constitutes imprisonment, citing legislation that allows such placements during the final months of a prison term. However, he failed to recognize that residential reentry can also serve purposes beyond supervised release, including as a condition of probation and as a form of prerelease custody.