Sentencing Guidelines – Supervised Released

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7^th Circuit Court of Appeals

Case Name: United States of America v. Joseph Canfield

Case No.: 20-3145

Officials: SYKES, Chief Judge, and FLAUM and EASTERBROOK, Circuit Judges.

Focus: Sentencing Guidelines – Supervised Released

Defendant-appellant Joseph Canfield was sentenced to prison and supervised release for possessing child pornography. In a subsequent proceeding for revocation of his supervised release, the district court sentenced Canfield to twenty months’ imprisonment and an additional five years’ supervised release, a term of supervised release which all parties referred to as “mandatory.” In this appeal, Canfield challenges the application of the additional five-year term as not actually mandatory but instead the result of a mutual mistake.

Going no further than our threshold waiver inquiry, we now affirm the judgment of the district court. Canfield had ample advance notice of the terms of his supervised release, was given a meaningful opportunity to object, indeed advanced several objections to those terms, and went so far as to affirmatively advance the argument he now challenges on appeal. Those actions amount to waiver.

Affirmed
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Derek A Hawkins is Corporate Counsel, at Salesforce.