The U.S. Court of Appeals for the Tenth Circuit has affirmed a district court's decision to revoke supervised release and impose additional prison time on Robert Lynn Harris, who violated the terms of his lifetime supervised release by possessing child pornography again in 2024.
In a January 29, 2026 order and judgment, the three-judge panel consisting of Circuit Judges Phillips, Ebel, and EID unanimously upheld the lower court's handling of Harris's repeat offense and supervised release violation.
According to court records, Harris was initially convicted of possessing child pornography in 2015. After completing a 120-month prison sentence for that conviction, he began serving a lifetime term of supervised release. However, while on supervised release in 2024, Harris was again found in possession of child pornography.
This second offense resulted in another criminal conviction, for which Harris received an additional 120-month prison sentence. The district court also revoked Harris's lifetime supervised release and imposed a two-year prison term for violating the conditions of his release.
Harris appealed the district court's decision to the Tenth Circuit, challenging both the revocation of his supervised release and the additional prison term. However, the appeals court found no error in the district court's actions.
The case, *United States v. Harris* (No. 24-8081), originated from the U.S. District Court for the District of Wyoming under case number 1:14-CR-00288-ABJ-1. The original 2015 conviction appears to have been handled by the same district court.
The Tenth Circuit panel decided the case without oral arguments, honoring the parties' request for a decision based solely on the written briefs and appellate record. This procedural approach is permitted under Federal Rule of Appellate Procedure 34(f) and Tenth Circuit Rule 34.1(G) when the court determines that oral argument would not significantly aid in the decision-making process.
The court's order notes that while this decision is not binding precedent, it may be cited for its persuasive value consistent with Federal Rule of Appellate Procedure 32.1 and Tenth Circuit Rule 32.1. The ruling can also serve as binding precedent under the doctrines of law of the case, res judicata, and collateral estoppel.
Supervised release violations in federal cases are governed by strict standards, particularly for serious offenses like child pornography. When a defendant violates the terms of supervised release, district courts have discretion to revoke the release and impose additional prison time, up to the maximum term authorized by statute.
For child pornography offenses, federal law provides for lengthy periods of supervised release, often extending to lifetime supervision for repeat offenders. The conditions of supervised release typically include restrictions on internet use, computer access, and contact with minors, among other requirements designed to prevent reoffending.
The fact that Harris received lifetime supervised release following his 2015 conviction suggests the court viewed him as presenting an ongoing risk to the community. His 2024 reoffense while under supervision appears to have validated those concerns and justified the district court's decision to impose additional penalties.
The Tenth Circuit's affirmance of the district court's decision reinforces the serious consequences facing defendants who violate supervised release terms, particularly in cases involving crimes against children. Courts have consistently taken a firm stance on supervised release violations, viewing them as evidence of a defendant's inability or unwillingness to comply with court-imposed restrictions designed to protect public safety.
This case also illustrates the challenges facing the criminal justice system in preventing recidivism among sex offenders. Despite serving the full 120-month sentence and being subject to lifetime supervised release with presumably strict monitoring conditions, Harris still managed to reoffend.
The ruling demonstrates the federal courts' commitment to enforcing the terms of supervised release and imposing meaningful consequences when defendants violate those terms. The combination of a new 120-month sentence for the 2024 offense plus the additional two-year term for the supervised release violation ensures that Harris will serve substantial additional prison time.
The case serves as a reminder to defendants on supervised release that violations carry serious consequences and that courts will not hesitate to impose additional prison terms when defendants fail to comply with release conditions. For Harris, the 2024 violation has effectively extended his time in federal custody significantly beyond what he would have served for the original 2015 conviction alone.
The Tenth Circuit's decision provides guidance to district courts within the circuit regarding the appropriate handling of supervised release violations in similar cases and reinforces the importance of strict enforcement of release conditions in protecting public safety.