UNITED STATES v. HOLMES (2025)

ORDER GRANTING MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE

Defendant Quinton Holmes pleaded guilty to a firearm charge and was sentenced by a judge in the Northern District of Ohio on August 20, 2021 to 15 months in custody to be followed by three years of supervised release. He began his supervised release term on February 8, 2023 and jurisdiction was transferred to this Court on March 2, 2023. The case is before the Court on the defendants motion to terminate supervised release, which is scheduled to end on February 7, 2026. The government filed a response indicating that it takes no position on Holmes's request.

After a defendant has served at least one year of a term of supervised release, the Court may order early termination “if it is satisfied that such action is warranted by the conduct of the defendant released and the interest of justice.” 18 U.S.C. § 3583(e)(1). “The expansive phrases ‘conduct of the defendant’ and ‘interest of justice’ make clear that a district court enjoys discretion to consider a wide range of circumstances when determining whether to grant early termination.” United States v. Hale, 127 F.4th 638, 640 (6th Cir. 2025) (quoting United States v. Melvin, 978 F.3d 49, 52 (3d Cir. 2020)). In making the determination, the Court must consider the factors generally prescribed for imposing a sentence initially under 18 U.S.C. § 3553(a). Ibid. And the Court must demonstrate that it considered those factors and “reasoned through the defendant's nonfrivolous arguments when ruling on a motion,” United States v. Tavarez, 141 F.4th 750, 757 (6th Cir. 2025) (citing United States v. Davis-Malone, 128 F.4th 829, 834 (6th Cir. 2025)) (cleaned up), although it need not specifically address each one, ibid. (stating that “the district court need not ‘articulate its analysis of each sentencing factor as long as the record demonstrates that the court considered the relevant factors’ ”) (quoting United States v. Watkins, 625 F.3d 277, 281 (6th Cir. 2010)). Those factors include the nature and circumstances of the offense and history of the defendant, the need for the sentence to provide adequate deterrence, the need to protect the public from further crimes of the defendant, the need to provide the defendant with needed educational or vocational training or other services, the range of sentences provided by the applicable sentencing guideline calculations, policy statements issued by the United States Sentencing Commission, the need to avoid sentencing disparities, and considerations of restitution. Ibid.

After evaluating those factors, “a district court must conclude that the early termination of supervised release is warranted both by the individual's conduct and also by the interest of justice.” United States v. Suber, 75 F. App'x 442, 444 (6th Cir. 2003). Factors include a defendant's “changed circumstances” such as “exceptionally good behavior by the defendant” that “render a previously imposed term ․ too harsh or inappropriately tailored to serve the general punishment goals of section 3553(a).” United States v. Lussier, 104 F.3d 32, 36 (2d Cir. 1997). However, “[t]he text [of section 3583(e)(1)] does not make “exceptionally good” conduct an absolute prerequisite to relief.” Hale, 127 F.4th at 641. “[S]uch behavior,” though, “remains a relevant consideration.” Hale, 127 F.4th at 642.

Holmes alleges in his motion that he has exhibited commendable compliance with his supervision terms. He remains violation-free. He obtained a full-time job and remains employed. He remains crime-free and has avoided contact with weapons and the people that carry them. Holmes also has become the primary caregiver for his elderly mother, who apparently is suffering from cognitive challenges. She lives in his hometown of Toledo, Ohio, and he says that the travel restrictions imposed by the supervised release conditions cause him some difficulty. He also enjoys a stable family situation with two daughters.

According to the defendant's supervising probation officer in this district, Holmes has successfully reintegrated into his community. He has paid all his monetary obligations for the offense. He presents no identifiable safety risk to victims or the public at large. He completed a concurrent term of parole with the Michigan Department of Corrections and received no misconduct reports from his parole officer.

The probation officer also confirms that Holmes has been employed full-time with Tire Wholesalers Inc. in Oak Park, Michigan, as a fork-lift driver. He has “continuously shown he has been able to maintain sobriety from drugs and alcohol as evidenced by his negative drug tests while on supervised release.” Holmes was formally assessed for substance abuse and mental health treatment in May 2023 and was not deemed an appropriate candidate at that time due to his long-term sobriety and overall stability with regard to his mental health. He has “not showcased any concerning behaviors in this area.”

The probation officer also confirms that Holmes has become the primary caretaker for his elderly mother who is suffering from dementia. There has been no new criminal activity while he has been on supervised release, and he has not been involved in his previous gang activity or relationships. The probation officer indicates that Holmes has done extremely well on supervised release.

The Post-Conviction Risk Assessment tool scores Holmes in the low/moderate range for reoffending. Per the PCRA, “persons in this category have a 17% arrest rate and a 6% revocation rate in the next 12 months.”

The probation officer's input is important and helpful. The agents in this district are attentive to those individuals in their charge, and their assessment of who needs attention to succeed and who seems to be doing well on their own provides valuable insight to the Court. With the limited personnel available, it is important to husband the resources and discharge from supervision those defendants who pose little risk of reoffending and have reached the limit of the assistance that supervised release was intended to furnish. Holmes fits the description of a defendant who has reached near maximum benefit from his supervisory term. All of the considerations found in 18 U.S.C. § 3553(a) favor the relief requested. With no objection from the government, it is appropriate to terminate supervision.

Accordingly, it is ORDERED that the defendant's motion for early termination of supervised release (ECF No. 3) is GRANTED.

DAVID M. LAWSON, United States District Judge