Sixth Amendment Does Not Apply to Supervised Release Proceedings

In US v. Spangle, No. 09-50508, defendant’s appeal from the twenty-four-month term of imprisonment imposed upon revocation of his supervised release, the court affirmed where 1) because the revocation of supervised release is indistinguishable from the revocation of parole, the Sixth Amendment had no application to supervised release proceedings; 2) in any event, any error in the revocation order was harmless because defendant admitted to violating the terms of his supervised release; and 3) the context of defendant’s threat did not necessitate the conclusion that there was an objective basis for recusal.

 

Related Resources

  • Read the Ninth Circuit’s Decision in US v. Spangle, No. 09-50508

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