The Sixth Circuit Court of Appeals recently upheld the sentencing of Deangelo Smith, who faced multiple violations of his supervised release and a conviction for being a felon in possession of a firearm. The court's decision, issued on October 20, 2026, is significant as it reinforces the legal consequences for individuals who violate supervised release terms, especially when new criminal conduct arises. Smith's case highlights the serious implications of firearm possession for individuals with prior felony convictions.
Smith's situation began when he was arrested for possessing a firearm during a traffic stop, violating the conditions of his supervised release. Following this, he was involved in a violent incident while detained, which led to the death of another inmate. The court's ruling emphasizes the importance of maintaining public safety and the need for appropriate sentencing in cases involving repeated criminal behavior.
Background
Deangelo Smith was initially sentenced in 2016 to 120 months in prison for a series of armed robberies where he brandished a gun. Following his release, he was placed on three years of supervised release starting June 4, 2024. However, he quickly violated the terms of his release by testing positive for marijuana and later admitting to having a firearm during a police stop.
While detained on these charges, Smith engaged in further criminal conduct, including crafting a shiv and assaulting another inmate. The most severe incident occurred on August 31, 2025, when Smith and three other detainees attacked another inmate, resulting in that inmate's death. This violent behavior while in custody prompted the courts to impose harsher sentences for his violations.
The Ruling
The Sixth Circuit, comprising Judges Julia Smith Gibbons, Jeffrey S. Sutton, and Stephanie Dawkins Davis, ruled to affirm Smith's sentence. The court found that Smith's arguments against the procedural and substantive reasonableness of his sentence lacked merit. Specifically, Smith contended that the district court improperly double counted his conduct from the August 31 incident in both his felon-in-possession sentence and his supervised release violation sentence.
The court stated, "Smith’s two cases were ‘separate matter[s] involving . . . separate sanctions.’" The judges clarified that the overlap in considering Smith's history and characteristics was permissible and did not constitute double counting. They noted that the district court had the discretion to consider the same conduct in separate cases, emphasizing that each sentence addressed distinct violations.
Furthermore, the court upheld the district court's decision to impose an upward variance in Smith's sentence due to the severity of his actions while in custody. The judges agreed that the district court adequately justified the increased sentence, citing the need for deterrence and public safety. The court highlighted that Smith's violent behavior posed a danger to others, reinforcing the rationale for a longer sentence.
Impact
This ruling has significant implications for individuals on supervised release, particularly those with prior felony convictions. It underscores the courts' commitment to ensuring that repeat offenders face stringent consequences for violations of their release terms. The decision also serves as a warning that engaging in further criminal activity while on supervised release can lead to severe penalties, including extended prison time.
The court's affirmation of the upward variance in sentencing reflects a broader trend in the judicial system to prioritize public safety and deterrence in cases involving firearms and violent behavior. This ruling may influence future cases where defendants argue against the imposition of consecutive sentences or upward variances based on their prior conduct.
What's Next
Smith's case can potentially be appealed to a higher court, although details were not available in the court filing regarding any plans for further legal action. As of now, Smith remains subject to the sentences imposed by the district court, which will serve as a critical precedent for similar cases in the future.