In United States v. Melvin, the 3rd Circuit clarified the standard for evaluating motions for early termination of supervision pursuant to 18 U.S.C. ยง 3583(e). The Court disavowed two prior non-precedential opinions that required termination “only when the sentencing judge is satisfied that something exceptional or extraordinary warrants it, or upon a showing of new or unforeseen circumstances.” The 3rd Circuit held that district courts need only consider (1) the enumerated statutory factors, (2) the conduct of the defendant, and (3) the interest of justice.
