United States v. Jamel Williams

── United States v. Jamel Williams ── Court: Court of Appeals for the Sixth Circuit Date: April 15, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0170n.06 No. 25-3497 UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Apr 15, 2026 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE ) NORTHERN DISTRICT OF JAMEL WILLIAMS, ) OHIO Defendant-Appellant. ) ) OPINION ) ) Before: GIBBONS, THAPAR, and LARSEN, Circuit Judges. LARSEN, Circuit Judge. Jamel Williams pleaded guilty to ten counts of uttering counterfeit obligations. He was sentenced to 36 months’ imprisonment to be followed by 3 years of supervised release. Williams then violated his release conditions on multiple occasions; in response, the district court revoked his supervised release and imposed an 18-month sentence to be followed by a new supervised-release term. Williams now appeals, challenging the reasonableness of his sentence and the additional term of supervised release. For the reasons that follow, we AFFIRM in part, VACATE in part, and REMAND. I. Like many Americans, Jamel Williams was a frequent Target shopper. But what distinguished Williams’ “Target Runs” was that he paid for his goods with counterfeit currency, passing a total of $4,000 in counterfeit bills between November 2015 and October 2016. See United States v. Williams, 807 F. App’x 505, 506 (6th Cir. 2020). For those offenses, he was No. 25-3497, United States v. Williams charged with violating 18 U.S.C. § 472 and pleaded guilty. Id. at 506–07. The district court imposed a sentence of 36 months’ imprisonment to be followed by a 3-year term of supervised release. Id. at 507. We affirmed his sentence. Id. at 511. Williams’ first supervised-release term began in June 2021. Yet by the end of October 2022, Williams had violated his conditions on seven occasions, mostly by using marijuana. Williams admitted the violations, and the district court sentenced him to 8 months’ imprisonment followed by 2 years of supervised release. Williams’ most recent term of supervised release began in June 2023. In March 2024, Williams again violated his release terms by testing positive for marijuana. Then, in August, he cashed a fraudulent $1,000 check at a liquor store. And later that month, he wrote several more fraudulent checks, totaling more than $3,000, at two different retail stores. He was charged for these offenses in two separate Ohio county courts and pleaded guilty. For the first bad check, he was sentenced to serve 7 months in prison. For the others, he was sentenced to 5 years of probation, ordered to pay restitution, and required to perform 100 hours of community service. The new state-law violations prompted the federal district court to schedule a supervised release violation hearing. Williams admitted the violations, and the court revoked his supervised-release term. The court calculated his Guidelines range as 6 to 12 months’ imprisonment. But the district court varied upward, sentenc