Full Opinion

USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 1 of 12 PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-4521 UNITED STATES OF AMERICA, Plaintiff – Appellee, v. ANDREW CHAFIN, Defendant – Appellant. Appeal from the United States District Court for the Eastern District of Virgina, at Richmond. John A. Gibney, Jr., Senior District Judge. (3:24-cr-00057-JAG-1) Argued: September 17, 2026 Decided: October 19, 2026 Before WILKINSON, KING, and RUSHING, Circuit Judges. Affirmed by published opinion. Judge Rushing wrote the opinion, in which Judge Wilkinson and Judge King joined. ARGUED: Salvatore M. Mancina, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Lauren Nicole Beebe, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee. ON BRIEF: Geremy C. Kamens, Federal Public Defender, Alexandria, Virginia, Joseph S. Camden, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Richmond, Virginia, for Appellant. Todd W. Blanche, Deputy Attorney General, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 2 of 12 RUSHING, Circuit Judge: Andrew Chafin violated the conditions of his supervised release and received a nine- month prison sentence. He appeals, arguing that the district court impermissibly considered the need to sanction his breach of trust when determining his revocation sentence. In United States v. Lewis, our Court rejected this argument and held that a district court may lawfully impose a revocation sentence to sanction a defendant’s breach of its trust. 90 F.4th 288, 299 (4th Cir.), cert. denied, 144 S. Ct. 2543 (2024). Chafin contends that the Supreme Court’s subsequent decision in Esteras v. United States, 145 S. Ct. 2031 (2025), abrogated this Court’s holding. We conclude that Lewis is still good law; therefore, we affirm. I. After pleading guilty to possessing a firearm as a convicted felon, see 18 U.S.C. § 922(g)(1), Chafin received a below-Guidelines prison sentence with a term of supervised release to follow. He began that supervision in May 2025, and he performed poorly. Within a few months, Chafin violated his supervised release conditions numerous times by using illegal substances, failing to report as directed or produce samples for drug testing, declining to participate in required addiction-recovery meetings and obtain a sponsor, and neglecting to pay his special assessment. In August 2025, Chafin’s probation officer petitioned for revocation of his term of supervised release. At the revocation hearing, Chafin admitted the violations, acknowledged his addiction, and asked the district court to put him back on supervision. The Government, for its part, outlined Chafin’s violation conduct and asked the district court to impose a 2 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 3 of 12 “significant period” of imprisonment so that Chafin would choose to reform his ways. J.A. 112. The district court responded, You request in addition to the period of incarceration, supervised release to follow that. He hasn’t done very well on it. We are hoping maybe this will slam some sense into him. J.A. 113. The Government took this as a summary of, and question about, its own position and answered with reasons why supervision would still be helpful. Defense counsel then argued for a sentence of time served. During his discourse, defense counsel asserted that the district court could not consider, among the revocation sentencing factors, “[s]anctioning for breach of trust.” J.A. 124. He acknowledged that Lewis foreclosed this argument but nevertheless sought to preserve it in light of Esteras. The district court revoked Chafin’s supervised release and turned to determining the appropriate sentence. The court first acknowledged its obligation to “consider some but not all” of the sentencing factors in 18 U.S.C. § 3553(a) and listed the permissible factors: I am to consider the nature and circumstance of the offense, the history and characteristics of the defendant, the need for the sentence imposed to afford adequate deterrence, protect the public, and provide him with needed educational or vocational training, medical care, or other correctional treatment. The kinds of sentences in the sentencing range established under the [G]uidelines. Any policy statements pertinent. The need to avoid unwarranted sentencing disparities among people with similar records. And the need to provide restitution. J.A. 127–128; see 18 U.S.C. §§ 3583(e), 3553(a)(1), (a)(2)(B)–(D), (a)(4)–(7). Applying these factors, the court balanced Chafin’s family support and need for training and treatment with his “bad drug problem,” defiance of rehabilitative opportunities, need for 3 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 4 of 12 deterrence, and conduct “violat[ing] the trust The Court put in him.” J.A. 128. Ultimately, the court imposed a within-Guidelines sentence of nine months’ imprisonment followed by 21 months of supervised release. Chafin appealed. II. On appeal, Chafin challenges the procedural reasonableness of his revocation sentence. We will affirm a revocation sentence if it is within the applicable statutory range and not plainly unreasonable. United States v. Crudup, 461 F.3d 433, 439–440 (4th Cir. 2006). “To determine whether a revocation sentence is plainly unreasonable, we first assess whether it is procedurally or substantively unreasonable, under a ‘deferential appellate posture.’” United States v. Walton, 145 F.4th 476, 486 (4th Cir. 2025) (quoting United States v. Moulden, 478 F.3d 652, 656 (4th Cir. 2007)). Relevant here, “[a] revocation sentence is procedurally reasonable if the district court adequately explains the chosen sentence after considering the Sentencing Guidelines’ nonbinding Chapter Seven policy statements and the applicable 18 U.S.C. § 3553(a) factors.” Id. (internal quotation marks omitted). Only if a sentence is unreasonable do we then assess whether it is “plainly” so, meaning that the unreasonableness is clear or obvious. Crudup, 461 F.3d at 439. Chafin contends that his revocation sentence is procedurally unreasonable because the district court considered the need to sanction his breach of trust, as shown by the court’s reference to “slam[ming] some sense into him” and the statement that Chafin “did violate the trust The Court put in him.” J.A. 113, 128. In Chafin’s view, sanctioning a breach of trust is not one of the factors a court can consider when revoking supervised release because it is not listed in 18 U.S.C. § 3583(e) and is retributive in nature. Further, although Chapter 4 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 5 of 12 Seven of the Sentencing Guidelines directs courts to sanction supervised release violations as breaches of trust according to their relative seriousness, Chafin argues that framework conflicts with Section 3583(e). We begin with what Chafin acknowledges: this Court has already rejected his argument. In Lewis, the defendant argued, as Chafin does here, that Chapter Seven’s “‘breach of trust’ theory for revocation sentences—under which ‘the sentence imposed upon revocation [of supervised release] [is] intended to sanction the violator for failing to abide by the conditions of the court-ordered supervision’”—is “conceptually indistinguishable” from the retributive sentencing factor that Section 3583(e) forbids district courts to consider. 90 F.4th at 293 (alterations in original) (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)). Such retributive considerations also arise, the defendant argued, where Chapter Seven “creates ‘three grades of . . . supervised-release violations’ . . . that are based on the relative seriousness of the violation” and then uses “the violation’s grade, combined with the defendant’s criminal history category, to determine the advisory sentencing range.” Id. (quoting U.S.S.G. § 7B1.1(a) and citing id. § 7B1.4). This Court rejected both contentions. As an initial matter, the Lewis Court acknowledged that a district court may not revoke supervised release “to punish the defendant for the offense.” Id. at 295. When sentencing a defendant to a term of imprisonment for his original crime of conviction, a district court must consider all the factors listed in 18 U.S.C. § 3553(a). That includes the four factors found in Section 3553(a)(2), which summarize the “four traditional purposes of sentencing”: (A) “retribution or punishment,” (B) “deterrence,” (C) “incapacitation,” 5 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 6 of 12 and (D) “rehabilitation.” Lewis, 90 F.4th at 293. But when a district court is deciding whether to impose, modify, or revoke a term of supervised release served after the defendant’s imprisonment, the court may consider only the Section 3553(a) factors listed in Section 3583. See 18 U.S.C. § 3583(c), (e). And Section 3583 omits from its list the factor at Section 3553(a)(2)(A), which is “the need for the sentence imposed . . . to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense.” 18 U.S.C. § 3553(a)(2); see 18 U.S.C. § 3583(c), (e). Thus, we have long recognized that courts cannot consider this “retribution factor” in supervised release determinations. Lewis, 90 F.4th at 295; see Crudup, 461 F.3d at 439. Against that statutory background, the Court in Lewis rejected the defendant’s challenges to Chapter Seven’s framework for revocation sentences. The Court first explained that the “offense” referenced in Section 3553(a)(2)(A) is the “offense of conviction for which the defendant was originally sentenced, not the new conduct violating his supervised release conditions.” Lewis, 90 F.4th at 297. Accordingly, Section 3583(e) prohibits a court from considering retribution for the original offense of conviction when imposing a revocation sentence. But Chapter Seven does not treat a revocation sentence as punishment for the original offense or for new criminal conduct. Instead, Chapter Seven treats revocation as a sanction for failing to abide by a court-ordered condition of supervision, “‘leaving the punishment for any new criminal conduct to the court responsible for imposing the sentence for that offense.’” Id. at 296 (emphasis omitted) (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)). In other words, the supervised release violation is sanctionable in a revocation proceeding because it breaches a condition 6 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 7 of 12 imposed as part of the original judgment—not because the revocation court is punishing a new criminal offense or exacting additional retribution for the original offense. Nor, Lewis held, is Chapter Seven unlawful because its grade classifications account for the seriousness of the violation. Section 3583(e)(3) authorizes courts to require the defendant to serve “all or part” of the supervised release term in prison. 18 U.S.C. § 3583(e)(3). Lewis reasoned that this discretion to determine how much of the term “to convert to imprisonment” necessarily implies authority to “assess the seriousness” of the violation conduct. Lewis, 90 F.4th at 298. And nothing in Section 3583(e) restricts a court from considering the relative seriousness of the conduct underlying the defendant’s supervised release violation. Id. Chapter Seven therefore “faithfully implements,” rather than contradicts, the governing statutes. Id. at 291. In Esteras, the Supreme Court confirmed that district courts may not consider retribution for a defendant’s original offense of conviction when deciding whether to revoke a term of supervised release. 145 S. Ct. at 2040; see id. at 2038 n.1 (citing Crudup, 461 F.3d at 439). As the Supreme Court explained, Congress’s decision to omit Section 3553(a)(2)(A) from the list of factors in Section 3583(e) bars district courts from considering “the need for the sentence imposed to ‘reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense,’ i.e., the retributive purposes of sentencing.” Id. at 2039 (quoting 18 U.S.C. § 3553(a)(2)(A)). And “offense” in Section 3553(a)(2)(A) means “the underlying crime of conviction, not the violation of the supervised-release conditions.” Id. at 2040. Given the meaning of “offense,” the Supreme Court was careful to “address only whether § 3583(e) precludes 7 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 8 of 12 [a] court from considering retribution for the underlying criminal conviction.” Id. at 2040 n.5. The Court expressly “t[ook] no position” on the lawfulness of Chapter Seven’s directive that a revocation sentence is “‘intended to sanction the violator for failing to abide by the conditions of the court-ordered supervision’” and “may ‘sanction’ an offender’s ‘breach of trust.’” Id. (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)). Chafin argues that Esteras abrogated Lewis. When a subsequent Supreme Court decision “clearly undermine[s]” our precedent, we must follow the Supreme Court. United States v. Williams, 155 F.3d 418, 421 (4th Cir. 1998). Accordingly, we are not bound by a prior decision of our Court “if its reasoning or holding is inconsistent with a Supreme Court decision.” United States v. Banks, 29 F.4th 168, 175 (4th Cir. 2022); see Short v. Hartman, 87 F.4th 593, 605 (4th Cir. 2023). We conclude that Esteras did not abrogate Lewis because their holdings and reasoning are compatible. In Esteras, the Supreme Court held that a court revoking a defendant’s supervised release may not consider retribution for the original crime of conviction. 145 S. Ct. at 2040. As Chafin concedes, Esteras explicitly “left open” whether Section 3583(e) allows the court to consider the need to sanction a defendant’s “‘violation of the conditions of [the] supervised release,’” which is the question that Lewis resolved. Opening Br. 13 (emphasis omitted) (quoting Esteras, 145 S. Ct. at 2040 n.5). Their holdings therefore do not conflict. As for the decisions’ reasoning, Chafin argues that Lewis cannot be reconciled with Esteras because breach of trust is not a factor enumerated in Section 3583(e) and sanctioning a breach of trust is inherently retributive. Neither argument persuades. 8 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 9 of 12 First, Chafin contends that breach of trust is an impermissible factor because it does not appear in what Esteras called Section 3583(e)’s “exhaustive” list, which “suppl[ies] the universe of factors that the district court can consider” in revocation proceedings. Esteras, 145 S. Ct. at 2042. He overlooks that Section 3583(e)’s list of factors expressly includes Section 3553(a)(4), which directs courts to consider the applicable Sentencing Commission guidelines or policy statements governing violations of supervised release. See also 18 U.S.C. § 3553(a)(5). Lewis relied on that provision in giving effect to Chapter Seven, see 90 F.4th at 295–296, 299, and Esteras acknowledged it when reserving judgment on whether a court may impose a revocation sentence to sanction a defendant’s breach of trust, see 145 S. Ct. at 2040 n.5. A district court that considers Chapter Seven’s framework therefore does not add an unenumerated factor to Section 3583(e). It gives effect to a consideration Congress expressly included. That framework also fits the task that Section 3583(e) assigns revocation courts: determining the appropriate response to a defendant having “violated a condition of supervised release.” 18 U.S.C. § 3583(e). “The consequences that flow from violation of the conditions of supervised release are first and foremost considered sanctions for the defendant’s ‘breach of trust’—his ‘failure to follow the court-imposed conditions’ that followed his initial conviction . . . .” United States v. Haymond, 139 S. Ct. 2369, 2386 (2019) (Breyer, J., concurring) (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)); see id. at 2393 (Alito, J., dissenting, joined by Roberts, C.J., Thomas & Kavanaugh, JJ.) (“The principal reason for assigning a penalty to a supervised-release violation . . . is that the violative act is a breach of trust.” (citing U.S.S.G. ch. 7, pt. A, intro. (3)(b)). And as Lewis explained, 9 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 10 of 12 the discretion Section 3583(e) affords in selecting a revocation sentence permits courts to assess the relative seriousness of that violation. See 90 F.4th at 298. Chapter Seven accordingly directs courts to “sanction[] ‘primarily the defendant’s breach of trust, while taking into account, to a limited degree, the seriousness of the underlying violation and the criminal history of the violator.’” Walton, 145 F.4th at 491 (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)). Second, Chafin asserts that sanctioning a breach of trust is unlawfully retributive after Esteras’s instruction that revocation courts “must consider the forward-looking ends of sentencing (deterrence, incapacitation, and rehabilitation), but may not consider the backward-looking purpose of retribution” under Section 3583(e). Esteras, 145 S. Ct. at 2041. This instruction, however, does not undermine the reasoning of Lewis. The Section 3553(a)(2)(A) retribution factor that Esteras forbids concerns retribution for “the underlying crime of conviction, not the violation of the supervised-release conditions.” Id. at 2040; see Lewis, 90 F.4th at 297. And Esteras took “no position on” whether courts may consider “retribution for the violation of the conditions of the supervised release.” Esteras, 145 S. Ct. at 2040 n.5 (emphasis omitted). Moreover, assessing the seriousness of a defendant’s breach of trust can inform supervised release’s forward-looking purposes and the revocation sentence appropriate to further those purposes. Supervised release “permits a defendant a kind of conditional liberty by allowing him to serve part of his sentence outside of prison, subject to conditions on his behavior.” Id. at 2039 (internal quotation marks omitted). Those conditions fulfill “rehabilitative ends” designed “to assist” a defendant in his “transition to community life.” 10 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 11 of 12 United States v. Johnson, 529 U.S. 53, 59 (2000). The district court thus relies on a relationship of trust with the defendant to help him reintegrate into society. When a defendant breaches that trust, the court often must consider how to rebuild it and “set the defendant back on a path to rehabilitation.” United States v. Williams, 169 F.4th 727, 731 (6th Cir. 2026). A defendant’s failure to comply with the conditions governing his return to the community also can inform the district court’s assessment of the need for deterrence and protection of the public. Accordingly, courts may frequently find it appropriate to consider a defendant’s past conduct violating supervised release conditions when assessing the need for a revocation sentence serving “forward-looking ends.” Esteras, 145 S. Ct. at 2041. As we explained in Lewis, Chapter Seven’s framework allows courts to “‘measur[e] the extent of the breach of trust’” and “‘sanction’” it consistent with Section 3583(e), without using revocation to exact retribution for the original offense. 90 F.4th at 298 (quoting U.S.S.G. ch. 7, pt. A, intro. (3)(b)). Esteras does not undermine that reasoning. With the applicable law settled, we turn to Chafin’s own revocation sentence. His procedural reasonableness challenge depends entirely on Lewis having been abrogated. Because Lewis remains binding, that challenge fails. Chafin concedes that the district court did not rely on any purported need to sanction him for his original offense of conviction. And the court did not impose the revocation sentence “as punishment for new criminal conduct.” Id. at 296. Instead, the court identified the permissible Section 3553(a) factors, addressed Chafin’s numerous violations of his supervised release conditions, and explained why a revocation sentence was necessary to deter Chafin and assist his rehabilitation. 11 USCA4 Appeal: 25-4521 Doc: 49 Filed: 10/19/2026 Pg: 12 of 12 These are permissible considerations; therefore, Chafin’s revocation sentence was procedurally reasonable. III. For the foregoing reasons, the judgment of the district court is AFFIRMED. 12