UNITED STATES OF AMERICA v. MALCOLM L. HOYLE - Articles

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UNITED STATES OF AMERICA v. MALCOLM L. HOYLE

Posted by: Azya Thornton on Aug 6, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Alex Thomason, KERRICK BACHERT, PSC, Bowling Green, Kentucky, for Appellant.

Attorneys 2: ON BRIEF: Jennifer J. King, UNITED STATES ATTORNEY’S OFFICE, Cleveland, Ohio, for Appellee.

Judge(s): United States District Court for the Northern District of Ohio at Cleveland

Court Appealed: CLAY, WHITE, and DAVIS, Circuit Judges

DAVIS, Circuit Judge. Malcolm Hoyle pleaded guilty to being a felon in possession of a firearm and admitted that the conduct underlying that offense was a violation of a condition of his supervised release. In a joint sentencing hearing that covered both the substantive felon-in- possession charge and the follow-on supervised-release violation, the district court imposed 96 months’ imprisonment for the felon-in-possession offense and 24 months for the supervised- release violation, to be served consecutively. Hoyle claims three errors. First, he contends that he never knowingly and voluntarily waived his right to a revocation hearing for the supervised- release violation, so we should remand the case for such a hearing. Second, he argues that the district court erroneously applied the sentencing factors delineated in 18 U.S.C. § 3553(a) during his sentencing on the violation, and this misapplication of the factors led to a procedurally unreasonable sentence. Third, he asserts that his sentence on the substantive offense is also procedurally unreasonable, because the district court improperly calculated his sentencing guidelines when it erroneously gave career-offender treatment to two of his prior convictions. His first and third claims of error lack merit. But because the district court clearly considered inapplicable statutory factors in fashioning Hoyle’s sentence for the supervised-release violation, we AFFIRM IN PART, REVERSE IN PART, and REMAND for further proceedings.

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