United States of America v. Jason A. Williams

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted June 20, 2025
Decided June 24, 2025
Before
DAVID F. HAMILTON, Circuit Judge
MICHAEL Y. SCUDDER, Circuit Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
No. 24-3197
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
JASON A. WILLIAMS,
Defendant-Appellant.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 3:17-cr-30181-SMY-1
Staci M. Yandle,
Judge.
O R D E R
Jason Williams appeals the sentence imposed upon the revocation of his
supervised release, but his appointed counsel asserts that the appeal is frivolous and
moves to withdraw. See Anders v. California, 386 U.S. 738, 744 (1967). We grant the
motion and dismiss the appeal.
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-3197 Page 2
A defendant who appeals a revocation order does not have an unqualified
constitutional right to counsel, so the Anders safeguards need not govern our review.
See Gagnon v. Scarpelli, 411 U.S. 778, 789–90 (1973); United States v. Eskridge, 445 F.3d 930,
932–33 (7th Cir. 2006). Even so, our practice is to apply them. See United States v. Brown,
823 F.3d 392, 394 (7th Cir. 2016). Counsel’s brief explains the nature of the case and
addresses issues that an appeal of this kind would typically involve. Because counsel’s
analysis appears thorough, and Williams did not respond to the motion, see C IR . R.
51(b), we limit our review to the subjects that counsel discusses. United States v. Wheeler,
814 F.3d 856, 857 (7th Cir. 2016).
In 2018, Williams pleaded guilty to possession with intent to distribute
methamphetamine. See 21 U.S.C. § 841(a)(1) and (b)(1)(B)(viii). He was sentenced to the
low end of the guidelines range—87 months—followed by four years of supervised
release. The court later reduced Williams’s sentence below the guidelines range to 70
months.
In 2023, a year after completing his prison term, Williams violated the terms of
his release. As he admitted at his revocation hearing, his violations included battery,
vandalism, speeding, and unlawfully possessing methamphetamine and alcohol. In
addition, he failed to participate in court-mandated substance-abuse programs, failed to
notify probation that he had been questioned by law enforcement, and failed to make
monthly payments towards his financial penalty. Based on these admissions, the district
court revoked Williams’s release and calculated a policy-statement range of 4–10
months’ imprisonment. But the court determined that an upward variance was
warranted and sentenced him to 12 months’ imprisonment, with two years’ supervised
release to follow.
Counsel tells us that Williams wishes to challenge only the reasonableness of his
sentence and not the revocation of his supervised release. Counsel therefore
appropriately declines to explore any challenge to the voluntariness of Williams’s
admissions or to the revocation decision. See Wheeler, 814 F.3d at 857.
Counsel first considers whether Williams could raise any nonfrivolous
procedural challenge to the sentence and rightly concludes he could not. The district
court correctly determined that Williams’s most serious offenses—possession of
methamphetamine and buprenorphine, as well as battery—were Grade B violations
under the Guidelines. See U.S.S.G. § 7B1.1(a)(2). For a defendant with a Grade B
violation and criminal history category of I, the policy-statement range is 4–10 months’

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No. 24-3197 Page 3
imprisonment. See U.S.S.G. § 7B1.4(a). Because Williams’s original drug-possession
offense was a Class B felony, see 21 U.S.C. § 841(a)(1) and (b)(1)(B)(viii); 18 U.S.C.
§ 3559(a)(2), the statutory maximum prison term for his revocation was three years.
See 18 U.S.C. § 3583(e)(3). Williams’s 12-month sentence does not exceed this limit.
Counsel also explores, but rightly rejects, a challenge to the substantive
reasonableness of Williams’s 12-month prison term. We review a revocation sentence
under a “highly deferential” standard, overturning only if it was “plainly
unreasonable.” United States v. Childs, 39 F.4th 941, 944–45 (7th Cir. 2022). We agree with
counsel that the court adequately considered the relevant sentencing factors in
§ 3553(a). See 18 U.S.C. § 3583(e). The court highlighted, for instance, the “very serious”
nature of Williams’s offenses, § 3553(a)(2)(A), as well as the danger he posed to the
public, see § 3553(a)(2)(C), based on his continued use of methamphetamine and
alcohol, combined with his reckless driving. The court also appropriately justified its
two-month upward variance, see U.S.S.G. § 7B1.4(a), based on Williams’s disregard for
the need to comply with his supervised-release conditions having received a reduced
and below-guidelines sentence on his underlying conviction.
Therefore, we GRANT counsel’s motion to withdraw and DISMISS the appeal.

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