When a federal judge revokes supervised release, how much explanation does the court owe the defendant? According to a new Fourth Circuit decision, the answer is: enough to show that the judge actually considered the defendant’s arguments for a lighter sentence.
In United States v. Celedon, decided January 30, 2026, the Fourth Circuit vacated a 36-month revocation sentence—the statutory maximum—because the district court failed to address the defendant’s mitigating circumstances. The ruling reinforces an important principle for anyone facing a federal supervised release violation: courts must engage with your arguments, not simply impose the harshest penalty without explanation.
What Happened in the Celedon Case
Francisco Celedon had previously been convicted of drug trafficking and illegal reentry. After serving his sentence, he was deported to Mexico. More than three years later, he was found in Virginia with over six kilograms of cocaine. This triggered both new federal charges and a petition to revoke his supervised release.
At the revocation hearing, Celedon’s attorney argued for a sentence within the advisory guideline range of 12 to 18 months. The defense raised several mitigating factors: Celedon was otherwise law-abiding, he supported his family, and—critically—he claimed his involvement in drug trafficking was coerced. Having grown up around cartel violence in Mexico, Celedon said he understood the brutal consequences of refusing a cartel’s demands.
The district court acknowledged that Celedon’s arguments would “typically be very, very compelling.” But the judge then imposed the statutory maximum of 36 months, citing the large quantity of drugs and Celedon’s prior similar conviction. The court made no mention of the coercion argument.
The Fourth Circuit’s Ruling
Writing for the majority, Judge Gregory held that the revocation sentence was “plainly unreasonable” because the district court failed to address Celedon’s nonfrivolous mitigation arguments. The court emphasized several key principles that apply in all federal revocation proceedings:
First, when imposing an above-guideline sentence, courts must provide “a more significant justification” than would be required for an in-range sentence. Here, the court doubled the high end of the guideline recommendation without explaining why such a dramatic departure was necessary.
Second, the “very purpose of a revocation hearing is to determine the gravity of the defendant’s breach of trust.” Celedon argued that his breach was less severe because he acted under duress. Whether or not the court believed him, it needed to acknowledge and address this argument. The court’s silence left the appellate court unable to determine whether the factor was considered at all.
Third, a breach-of-trust analysis must be individualized. Simply noting that a defendant violated the law again is not enough when the defendant has offered a specific explanation for why that violation occurred.
The Dissent’s Perspective
Chief Judge Diaz dissented, arguing that the district court said enough. In his view, when the judge acknowledged that the defense arguments would “typically” be compelling but then explained why other factors outweighed them, that was sufficient. The dissent also noted that Celedon’s duress claims were “vague and unsubstantiated” and that any procedural error was harmless.
The majority disagreed, holding that the government failed to prove the error had no “substantial and injurious effect” on the outcome.
Why This Case Matters for Federal Defendants
Supervised release violations are common, and the consequences can be severe. Unlike initial sentencing, revocation hearings operate under different—and in some ways less protective—procedural rules. But Celedon confirms that defendants retain important rights at revocation, including the right to have their mitigation arguments actually considered.
For defense attorneys, the case underscores the importance of building a complete record. The Fourth Circuit relied heavily on the fact that Celedon’s coercion argument was preserved through statements at both the sentencing and revocation hearings. When a court imposes the maximum sentence without addressing defense arguments, that silence can become the basis for appeal.
For defendants facing revocation, the case offers hope: even when the government seeks the statutory maximum, courts must explain why they’re rejecting your arguments for leniency. A conclusory reference to “breach of trust” is not enough when you’ve offered specific reasons why your circumstances warrant a lighter sentence.
Contact a Federal Criminal Defense Attorney
If you or a loved one is facing a supervised release revocation in federal court, the stakes are high. At The Chetson Firm, we represent clients in federal criminal matters throughout North Carolina and the Fourth Circuit. Contact us today to discuss your case.