Case Citator › United States v. Brown

United States v. Brown

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Eleventh Circuit
Citation
224 F.3d 1237
Decided
Confirmed treatments
1
Flagged citations read
34 of 34
Citing cases (total)
34
Treatment dates
2014
Overruled in part
A reviewed court has overruled part of this case’s holding. United States v. Brown was overruled in part on rehabilitation-based imprisonment after revocation of supervised release. In United States v. Vandergrift, the Eleventh Circuit held that Tapia v. United States bars using rehabilitation to impose or lengthen that prison term.
More on how this was screened

Brown's separate rules for mandatory revocation remain in force; later Eleventh Circuit opinions continue to apply them. All 34 flagged citations have been read, and the confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

34 later cases cite United States v. Brown; 34 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Brown?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Eleventh Circuit rejected Brown's permission to consider rehabilitation when setting imprisonment after revocation of supervised release.

    United States v. Vandergrift · Eleventh Circuit · filed

    In doing so, we recognize that Tapia abrogates our holding in United States v. Brown, where we stated that “a court may consider a defendant’s rehabilitative needs when imposing a specific incarcerative term following revocation of supervised release.” 224 F.3d 1237, 1240 (11th Cir. 2000). Tapia made clear that prison is not to be viewed by sentencing judges as rehabilitative. And that holds true whether a person is initially being sent to prison or being sent back to prison after a period of supervised release.
    Read the full opinion on CourtListener →

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