Case Explained: UNITED STATES OF AMERICA v. CODY ZANE STEVENSON

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-17 The Fourth Circuit affirmed the district court’s judgment revoking Cody Zane Stevenson’s supervised release and imposing a nine-month prison sentence plus twelve months of supervised release. The court held that the district court did not commit reversible error by denying a motion to dismiss the revocation proceedings, noting that only Stevenson’s counsel moved to dismiss while the prosecutor and probation officer did not, and that Stevenson admitted to eight violations of his supervision conditions under 18 U.S.C. § 3583(e)(3). Regarding the sentence, the court applied the abuse of discretion standard, reviewing for procedural and substantive reasonableness with a deferential posture. The court found the sentence procedurally reasonable because the district court correctly calculated the advisory policy statement range under U.S. Sentencing Guidelines Manual § 7C1.5, considered the factors in 18 U.S.C. § 3553(a), and adequately explained its reasoning for the nine-month term to sanction breaches of trust and deter future conduct. The court further determined the sentence was substantively reasonable, rejecting Stevenson’s arguments regarding rehabilitation and noncustodial options given his multiple violations. Additionally, the court rejected Stevenson’s claim that a miscalculation of his original release date invalidated the revocation, citing *United States v. Johnson*, 529 U.S. 53 (2000), to establish that any excess time served on an original sentence does not automatically reduce the term of supervised release. The court also noted that while the district court briefly mentioned “respect for the law,” a factor generally impermissible under *Esteras v. United States* for revocation sentencing, any such error was not plain or obvious and did not affect Stevenson’s substantial rights. The practical consequence is that the judgment of revocation and sentence is final and enforceable. The court also issued instructions pursuant to *Anders v. California*, requiring counsel to inform Stevenson of his right to petition the Supreme Court for further review and outlining the procedure if counsel believes such a petition would be frivolous. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.