United States v. Mariel Watson

── United States v. Mariel Watson ── Court: Court of Appeals for the Fourth Circuit Date: June 08, 2026 Category: General USCA4 Appeal: 24-4588 Doc: 48 Filed: 06/08/2026 Pg: 1 of 6 PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 24-4588 UNITED STATES OF AMERICA, Plaintiff – Appellee, v. MARIEL WATSON, Defendant – Appellant. Appeal from the United States District Court for the District of South Carolina, at Charleston. Richard Mark Gergel, District Judge. (2:17−cr−01044−RMG−1) Argued: May 8, 2026 Decided: June 8, 2026 Before WILKINSON, NIEMEYER, and BENJAMIN, Circuit Judges. Vacated and remanded by published opinion. Judge Wilkinson wrote the opinion, in which Judge Niemeyer and Judge Benjamin joined. ARGUED: Jeremy A. Thompson, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Columbia, South Carolina, for Appellant. Andrea Gwen Hoffman, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee. ON BRIEF: Bryan P. Stirling, United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee. USCA4 Appeal: 24-4588 Doc: 48 Filed: 06/08/2026 Pg: 2 of 6 WILKINSON, Circuit Judge: After Mariel Watson violated the terms of his supervision, the district court sentenced him to 41 months in prison followed by nearly 21 months in home detention. We vacate Watson’s sentence and remand for resentencing. Home detention “may be imposed only as an alternative to incarceration.” 18 U.S.C. § 3563(b)(19). That means the district court could not sentence Watson to a combination of incarceration and home detention exceeding the 48-month maximum term of incarceration permitted by 18 U.S.C. § 3583(e)(3). I. In 2018, Watson pled guilty to two felonies. The district court sentenced him to prison followed by a term of supervised release. If Watson did not abide by the conditions of his supervision, he risked being sent back to prison for up to 48 months and being placed in supervised release for up to the rest of his life. 18 U.S.C. § 3583(e)(3), (h), (k). These potential repercussions failed to ensure Watson’s good behavior. Almost immediately upon leaving prison, he violated several terms of his supervision. The district court accordingly revoked his supervised release and sentenced him to 41 months in prison followed by a lifetime of supervised release. One of the conditions of Watson’s supervision was home detention for a period of 629 days, or nearly 21 months. See id. § 3563(b)(19). The day after his revocation hearing, Watson moved for reconsideration of his sentence. He claimed he could not receive more than 7 months of home detention given that the maximum term of incarceration permitted by § 3583(e)(3) was 48 months and he 2 USCA4 Appeal: 24-4588 Doc: 48 Filed: 06/08/2026 Pg: 3 of 6 had already been sentenced to 41 months in prison. For support, he turned to § 3563(b)(19), which states that home detention “may be imposed only as an alternative to incarceration.” The district court denied Watson’s motion. It held that periods of home detention do not count toward the maximum term of incarceration permitted by § 3583(e)(3) because home detention is distinct from incarceration. Watson timely appealed. II. Watson’s motion for reconsideration was i