U.S. v. Canfield

In proceeding to revoke defendant’s supervised release, defendant waived any challenge to Dist. Ct.’s ultimate imposition of additional 5-year term of supervised release, where defendant contended that said term was imposed due to parties’ mutual belief that said term of supervised release was mandatory. While defendant argued on appeal that additional 5-year term of incarceration was not actually mandatory, defendant waived such challenge, where defendant had ample advanced notice in Dist. Ct. of terms of supervised release, but made no objection to instant sentencing range that included instant 5-year minimum supervised release. Also, record showed that defendant’s counsel had affirmatively advanced instant 5-year mandatory-minimum term of supervised release. Additionally, Ct. of Appeals noted that defendant had potential ineffective assistance of counsel argument in any future collateral review petition.