United States of America v. William D. Dickerson

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted July 14, 2026 *
Decided July 14, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
KENNETH F. RIPPLE, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 25-1881
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
WILLIAM D. DICKERSON,
Defendant-Appellant.
Appeal from the United States District
Court for the Central District of Illinois.
No. 04-CR-20055-001
Michael M. Mihm,
Judge.
O R D E R
William Dickerson has served his 20-year sentence for conspiracy to distribute
cocaine and is now on supervised release. He appeals from the district court’s order
denying his request to terminate his supervision. See 18 U.S.C. § 3583(e)(1). Because the
district court did not abuse its discretion in denying the motion, we affirm.
* We have agreed to decide the case without oral argument because the briefs
and record adequately present the facts and legal arguments, and oral argument would
not significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-1881 Page 2
In September 2004, Dickerson was indicted on two counts of conspiracy to
distribute more than 5 kilograms of powder cocaine and more than 50 grams of cocaine
base. 21 U.S.C. §§ 841(a)(1), (b)(1)(A), and 846. The government filed notice of its intent
to seek an enhanced sentence under 21 U.S.C. § 851(b), citing Dickerson’s
1997 conviction for possessing an unspecified controlled substance in Illinois for which
he was sentenced to 180 days’ imprisonment and 25 months’ probation. See People v.
Dickerson, No. 96-CF-314 (Ill. Cir. Ct. Mar. 14, 1997).
Dickerson pleaded guilty to the federal charges via a written agreement. The
agreement stated that he was subject to a mandatory minimum sentence of 20 years’
imprisonment and 10 years’ supervised release on each count because of his 1997 state
drug conviction. The sentencing court imposed 20 years’ imprisonment and 10 years’
supervised release on each count to run concurrently.
While incarcerated, Dickerson was convicted of assaulting a federal employee
and sentenced to 70 months’ imprisonment. The court also imposed 3 years’ supervised
release to run concurrently with his 10-year term. See United States v. Dickerson, No. 09-
cr-10096-MMM-1 (C.D. Ill. June 11, 2010).
In February 2024, Dickerson completed his terms of imprisonment and began
supervised release. Just over a year later, in April 2025, Dickerson filed a motion
seeking to terminate his supervision, arguing that the relevant factors under 18 U.S.C.
§ 3553(a) counseled in favor of his discharge from supervision. Dickerson pointed to his
accomplishments during his short time on release: He earned his paralegal certificate,
passed a three-hour college-placement test, enrolled in multiple college-level writing
courses, and obtained employment at an auto repair shop where he details cars. And he
added that his 19-plus years in prison and zero infractions while on supervision
showed that he had been adequately deterred from further criminal activity and posed
no threat to the public. He argued that supervision hinders his career development
because he cannot work as a paralegal or travel to networking events. He also argued
that after our decision in United States v. Ruth, 966 F.3d 642 (7th Cir. 2020), if he were
sentenced today, he would face a maximum term of only five years’ supervision.
The district court denied the motion. It explained that Dickerson’s supervision is
set to end in 2034, and though he showed positive progress, remained sober, and
secured employment, Dickerson was classified “at a High-Risk Level” and required
monthly contact with his probation officer. Based on these facts, the court found that
Dickerson “would benefit from continued supervision at this time.” After stating that it

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No. 25-1881 Page 3
considered the factors in § 3553(a), the district court determined that early termination
was not warranted and not “in the interest of justice at this time.”
On appeal, Dickerson first argues that the district court abused its discretion by
failing to consider adequately the factors under § 3553(a) and that its ruling lacks
specificity. A district court abuses its discretion in denying a motion to terminate
supervised release only when it “commits a serious error of judgment, such as the
failure to consider an essential factor.” United States v. Lowe, 632 F.3d 996, 997–98
(7th Cir. 2011). Although the court must consider the § 3553(a) factors, it does not need
to respond to every argument or make explicit findings as to each relevant factor. See id.
at 998; United States v. Estrada, 135 F.4th 566, 570 (7th Cir. 2025). Here, the district court
recognized Dickerson’s positive progress, sobriety, and employment, and balanced his
achievements with the need to deter future crime and protect the public by
acknowledging that Dickerson’s risk level required monthly contact with his probation
officer. Though Dickerson insists that the court considered his risk of recidivism
without explicitly addressing the career limitations resulting from supervision, the
record shows that the court considered the relevant factors. Lowe, 632 F.3d at 998.
Next, Dickerson argues that the district court failed to consider his argument that
if he were sentenced today, under Ruth, his maximum term of supervision would be
only five years. But Ruth does not have retroactive effect. See United States v. Cotton,
108 F.4th 987, 991 (7th Cir. 2024), cert. denied, 145 S. Ct. 1214 (2025). So even if
Dickerson’s 1997 conviction would no longer qualify as a predicate offense for a
statutory sentencing enhancement under § 841, a point on which we express no opinion,
he remains convicted and sentenced under the law as it was in 2004. Id. And although
the district court did not address this argument expressly, it adequately considered
Dickerson’s need for further supervision given the length of his remaining term and
classification at a high-risk level.
Lastly, Dickerson tells us that after the district court denied his motion and he
filed this appeal, his risk level was reduced. On this basis, he asks us to reverse. But we
cannot reverse based on evidence not before the district court. In an order denying
Dickerson’s request to proceed in forma pauperis on appeal, the district court stated it
would consider another request for early termination should Dickerson’s “risk level
decrease and probation no longer be beneficial to him.” Nothing about the outcome of
this appeal precludes Dickerson from re-filing a motion for early termination in the
district court based on his reduced risk level.
AFFIRMED

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