UNITED STATES v. AN (2026)

Order

Before the Court is Defendant Guangyang An's motion for early termination of supervised release pursuant to 18 U.S.C § 3583(e)(1), or in the alternative, to modify Ms. An's “conditions of supervision to permit her to travel to China for sixty (60) days this summer.” (ECF No. 295.) On May 19, 2026, the Court granted Ms. An's motion to travel internationally for two weeks provided that Ms. An provides copies of her travel itinerary, contact and lodging information to her probation officer, (Dkt. Order dated May 19, 2026). Thus, only Ms. An's motion for early termination of supervised release remains before the Court. (ECF No. 295, the “Motion” or “Mot.”) The Government opposes the Motion. (ECF No. 296, the “Opp.”) The United States Probation Department (“Probation”) takes no position on the Motion. For the reasons set forth below, having considered the parties’ filings, the factual record, applicable law, the relevant 18 U.S.C. § 3553(a) sentencing factors pursuant to § 3583(e)(1), and the need for ongoing supervision, Ms. An's Motion for early termination of her supervised release is respectfully DENIED.

DISCUSSION

“Courts do not order early termination of supervised release as a matter of course.” United States v. Stein, No. 09-CR-377 (RPK), 2020 WL 4059472, at *2 (E.D.N.Y. July 19, 2020) (citation modified). Rather, early termination “is a discretionary decision made by the district court.” United States v. Sheckley, No. 96-cr-1786, 1997 WL 701370, at *1 (2d Cir. Nov. 10, 1997) (summary order).

The Court may only terminate supervised release after considering certain § 3553(a) sentencing factors but a district court “is not required to discuss each and every sentencing factor in exercising its discretion.” United States v. Torres, No. 21-cr-2511, 2022 WL 17087048, at *3 (2d Cir. 2022) (citing United States v. Christie, 736 F.3d 191, 196 (2d Cir. 2013)). “A statement that the district court has considered the statutory factors is sufficient.” United States v. Gammarano, 321 F.3d 311, 315-16 (2d Cir. 2003) (citation modified).

Ms. An argues that her (i) steady employment and her role as the primary caretaker of her young children; (ii) plea to only a single count of conspiracy to commit visa fraud and lack of criminal history otherwise; and (iii) history of compliance with her supervised release terms weigh in favor of early termination. (Mot. at 3.)

The Court commends Ms. An's steady employment, caregiving responsibilities, and history of compliance with her supervised release terms. But “simply complying with the terms of supervised release does not generally justify early termination.” United States v. Stacharczyk, 719 F.Supp.3d 243, 246 (W.D.N.Y. 2024) (citation modified). Compliance with supervised release does not automatically constitute “exceptional circumstances” warranting early termination. See United States v. Berrios, No. 95-CR-84 (PKL), 2010 WL 1010022, at *2 (S.D.N.Y. Mar. 16, 2010) (denying defendant's motion for early termination of supervised release on the grounds that defendant's “continued compliance with her terms of supervision, good attitude, and positive work ethic” do not constitute an exceptional case); United States v. Wheeler, No. 20-CR-492, 2025 WL 1295610, at *2 (S.D.N.Y. May 5, 2025) (denying early termination of supervised release because “successful compliance with the conditions of his supervised release to date” along with “steady employment” are “what is expected of a person under ․ supervised release and does not warrant early termination”); United States v. Medina, 17 F. Supp. 2d 245, 247 (S.D.N.Y. 1998) (“While [defendant's] post-incarceration conduct is apparently unblemished, this alone cannot be sufficient reason to terminate the supervised release, since if it were, the exception would swallow the rule.”).

Ms. An identifies no “changed circumstances” since imposition of her supervised release terms that “render a previously imposed term or condition of release either too harsh or inappropriately tailored.” United States v. Lussier, 104 F.3d 32, 36 (2d Cir. 1997). In considering “the nature and circumstances of the offense,” 18 U.S.C. § 3553(a)(1), the Court again notes that it exercised its discretion in imposing a very lenient sentence of only two days of incarceration followed by two years of supervised release. (ECF No. 269.) To grant Ms. An release from half of her sentence thus fails to “afford adequate deterrence to criminal conduct,” 18 U.S.C. § 3553(a)(2) or otherwise serve the goals of sentencing. Accordingly, ongoing supervision is still necessary and shall continue.

CONCLUSION

For the reasons set forth above, Ms. An's motion for early termination of supervised release is respectfully DENIED.

So ordered.

Kiyo A. Matsumoto, United States District Judge