Case Explained: UNITED STATES OF AMERICA v. DEMETRIE MASSEY

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-26 The Fourth Circuit affirmed the district court’s judgment revoking Demetrie Massey’s supervised release and imposing a new term of supervised release. The court applied a plain error standard of review to Massey’s primary argument, which was not raised in the district court, requiring him to demonstrate that an error occurred, was plain, affected his substantial rights, and seriously affected the fairness or integrity of the proceedings. The court held that even if the district court erred by considering the severity of the breach of trust as a form of retribution for the violation, such an error could not be considered “plain” under current Fourth Circuit precedent following *Esteras v. United States*, which distinguished between retribution for the underlying crime and retribution for the supervision violation. Furthermore, the court found that any potential error did not affect Massey’s substantial rights because there was no reasonable probability that the outcome would have been different given the district court’s full explanation of the sentence. Regarding procedural and substantive reasonableness, the court applied the standard that a revocation sentence is reasonable if the district court adequately explains its decision after considering the Sentencing Guidelines’ Chapter Seven policy statements and the factors set forth in 18 U.S.C. § 3553(a). The court concluded that the record supported the conclusion that the sentence was both procedurally and substantively reasonable, resulting in the affirmation of the revocation judgment without oral argument. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.