Third Circuit - General Application Issues

United States v. Seighman, 966 F.3d 237 (3d Cir. 2020). 18 U.S.C. § 3583(g), which carries a mandatory minimum sentence of one day in prison, does not violate the Sixth Amendment by requiring mandatory imprisonment without the right to jury trial. Comparing the provision to 18 U.S.C. § 3583(k), which the Supreme Court found unconstitutional in United States v. Haymond, subsection (g) is more akin to ordinary revocation and less like punishment for a new offense.

United States v. Brito, 979 F.3d 185 (3d Cir. 2020). The court committed plain error when it misstated the defendant’s criminal history and history of deportations. The error went to the core of the defendant’s request for a lenient sentence and not correcting the error would undermine the integrity of the proceeding.