Alexis Hoag-Fordjour

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Token Triumph: Esteras v. United States Reinforces, Rather than Restrains, Carceral Logic

After Esteras v. United States, federal judges can no longer revoke supervised release as retribution for a defendant’s underlying conviction. However, the Court declined to address whether judges can revoke supervision as retribution for a defendant’s post-release conduct. This essay argues that the decision leaves intact a practice that threatens to undermine the original rehabilitative goals of supervision.