Exceptional Conduct Not Required for Early Termination of Supervised Release.

 In United States v. Hale, --- F.4th --- (6th Cir. 2025), the Sixth Circuit vacated a denial of early termination of supervised release because the prior Sixth Circuit opinions relied on by the district court incorrectly held that early termination is only warranted upon a showing of exceptionally good behavior. Mr. Hale was on ten years’ supervised release in connection with his conviction for violating the Sex Offender Registration and Notification Act. About four-and-a-half years into his supervised release term, Mr. Hale moved for early termination with no opposition from the government. In support, he offered letters from his state probation officer, therapist, and long-time friend attesting to his compliance. Although the district court praised Mr. Hale for his “positive behavior,” it cited United States v. Atkin, 38 F. App’x 196, 198 (6th Cir. 2002) for the proposition that “[e]arly termination of supervised release is a discretionary decision that is only warranted in cases where the defendant shows changed circumstances – such as exceptionally good behavior,” and held that Mr. Hale’s conduct did not satisfy that high standard.

The Sixth Circuit agreed with Mr. Hale that Atkin and subsequent unpublished decisions misstated the standard set out in 18 U.S.C. § 3583(e)(1), which requires the district court to determine whether early termination “is warranted by the conduct of the defendant released and the interest of justice,” in addition to certain § 3553 factors, and does not require exceptional conduct as a prerequisite to early termination. It thus remanded the case for reconsideration under the proper legal standard.