Case Explained: UNITED STATES OF AMERICA v. DUANE CURTIS JACKSON

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-05 The fourth-circuit affirmed the district court’s decision to revoke supervised release but vacated the resulting sentence and remanded the case for resentencing due to a procedural error under *United States v. Rogers*. The court held that the district judge violated the rule established in *Rogers* and clarified in *United States v. Singletary* by failing to orally pronounce four special conditions of supervised release during the revocation hearing, despite including them in the written judgment. Because these discretionary conditions were not mentioned in open court, the sentence was invalid. Although counsel filed an *Anders* brief questioning only the reasonableness of the sentence and found no other meritorious grounds for appeal after a full record review, the court determined that the *Rogers* error required vacating the entire sentence rather than just the conditions. Consequently, the defendant will undergo a new sentencing hearing where the district court must orally impose any applicable special conditions of supervised release. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.