United States v. Steven Hessen, Jr.

Appellant Steven Hessen invokes an intriguing, if minor, twist in the legislative history of the sentencing provisions in Title 21 U.S.C. section 841 in order to argue that the district court illegally imposed a term of supervised release as part of his sentence. While we find no error in the imposition or length of the post-confinement monitoring, we VACATE the sentence as to “supervised release” and REMAND for the imposition of an equal period of “special parole.”

The grand jury originally indicted Hes-sen for conspiring to possess with intent to distribute and conspiring to distribute…