United States v. Andrew Hulen

OPINION

CLIFTON, Circuit Judge:

The issue in this case is whether admissions made during mandatory sex-offender treatment may be used against a defendant to revoke supervised release. Answering that question requires us to consider whether a proceeding to revoke supervised release is a “criminal case” for purposes of the Fifth Amendment right against self-incrimination.

While on supervised release, Andrew Hulen violated various conditions of his release. He admitted those violations during sex-offender treatment, in which he was required to participate as a condition of his release. Based on…