United States v. Laphonse Young

── United States v. Laphonse Young ── Court: Court of Appeals for the Eleventh Circuit Date: April 29, 2026 Category: NEW USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 1 of 10 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11678 Non-Argument Calendar ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus LAPHONSE YOUNG, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Alabama D.C. Docket No. 1:09-cr-00029-JB-B-1 ____________________ Before LUCK, LAGOA, and BLACK, Circuit Judges. PER CURIAM: Laphonse Young appeals the district court’s revocation of his term of supervised release. Young argues that (1) the district court lacked jurisdiction under 18 U.S.C. § 3583(i) to revoke his USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 2 of 10 2 Opinion of the Court 25-11678 term of supervised release after it expired; (2) the district court abused its discretion by admitting hearsay evidence during the rev- ocation hearing; and (3) the district court erred by failing to provide Young the opportunity to object to a model-search condition for his new term of supervised release. After review, 1 we affirm. I. DISCUSSION A. Jurisdiction “A term of supervised release ends on its date of expiration.” United States v. Murat, 132 F.4th 1347, 1350 (11th Cir. 2025). A dis- trict court lacks jurisdiction to revoke a defendant’s term of super- vised release once it expires except under certain statutory excep- tions. See United States v. Okoko, 365 F.3d 962, 964 (11th Cir. 2004). Recently, the Supreme Court reviewed a circuit split on the issue of whether district courts can revoke a defendant’s term of supervised release after it expires based on actions taken after the expiration solely because the defendant absconded while under su- pervision. Rico v. United States, No. 24-1056, 607 U.S. ---, manuscript op. at *3-4 (U.S. Mar. 25, 2026). The Supreme Court held that dis- trict courts cannot revoke a defendant’s term of supervised release 1 “We review questions concerning a district court’s subject matter jurisdic- tion de novo.” United States v. Murat, 132 F.4th 1347, 1349 (11th Cir. 2025). We review a revocation of supervised release and evidentiary issues for abuse of discretion. United States v. Frazier, 26 F.3d 110, 112 (11th Cir. 1994); United States v. Novaton, 271 F.3d 968, 1005 (11th Cir. 2001). “We review de novo whether a district court has given a defendant the required opportunity to ob- ject to its factual and legal findings.” United States v. Mosely, 31 F.4th 1332, 1334 (11th Cir. 2022). USCA11 Case: 25-11678 Document: 27-1 Date Filed: 04/29/2026 Page: 3 of 10 25-11678 Opinion of the Court 3 in that way because there was no statutory basis for extending a defendant’s term of supervised release based on abscondment. Id. at *4-12. In reaching its decision, the Supreme Court contrasted the judge-made abscondment rule with statutory provisions that expressly allow di