There were three summary orders from the circuit today.
Remanded again: In United States v. White, the circuit reaffirmed that the district court must consider material post-sentencing conduct when resentencing a defendant. Ms. White’s case had already been remanded by the circuit once before because the district judge did not make factual findings to support a sentence enhancement. At the resentencing, the district court made ambiguous comments suggesting that it was ignoring her post-sentencing rehabilitation. The circuit, therefore, sent Ms. White’s case back to the district judge again. This time, the judge must consider whether the evidence of Ms. White’s rehabilitation merited a reduced term of supervised release.
Two affirmances: In United States v. Galanis, the circuit upheld the district court’s revocation of bail pending trial because there was probable cause that the defendant had continued his criminal activity; and, in United States v. Sturgis, the circuit …