United States v. Kendall: Supervision Revocation and Sentencing Mootness

This epsiode from the Fifth Circuit Court of Appeals addresses an appeal by William Scott Kendall regarding the conditions of his supervised release. Although Kendall’s original supervision was revoked a second time during the appeal process, the court determined the case was not moot because the subsequent revocation was based on conditions that may have been invalidly imposed. The court found that the district court failed to orally pronounce specific requirements, such as home detention, during sentencing, thereby depriving the defendant of his due process right to notice and an opportunity to object. Because the written judgment included more burdensome requirements than the oral sentence, the appellate court ruled that the district court abused its discretion. Consequently, the court vacated the unpronounced conditions and remanded the case to amend the judgment, while dismissing the remainder of the appeal.