The U.S. Court of Appeals for the 11th Circuit vacated and remanded the prison sentence of Randolph Ashlock after determining that a federal district court exceeded statutory sentencing limits when revoking his supervised release. The three-judge panel granted Ashlock's unopposed motion for summary reversal in a per curiam opinion filed Jan. 26, 2026.

Ashlock was originally convicted on federal charges for possession of child pornography involving a minor under 12 years of age, in violation of 18 U.S.C. § 2252A(a)(5)(B) and (b)(2), and receipt of child pornography, in violation of 18 U.S.C. § 2252A(a)(2)(B) and (b)(1). Following his initial conviction, Ashlock was placed on supervised release but subsequently violated the terms of that supervision.

When the U.S. District Court for the Middle District of Florida revoked Ashlock's supervised release, it imposed a sentence of 24 months on the possession count and 37 months on the receipt count, with the sentences running concurrently. However, Ashlock challenged the 37-month sentence on the receipt count, arguing it exceeded the statutory maximum permitted under federal law.

In his appeal, Ashlock filed an unopposed motion for summary reversal, contending that the district court's 37-month sentence on the receipt count violated the statutory limits established in 18 U.S.C. § 3583(e)(3). The provision sets maximum terms of imprisonment that courts may impose when revoking supervised release, with different limits based on the class of the original offense.

The 11th Circuit panel, comprised of Circuit Judges Luck, Lagoa, and Brasher, agreed with Ashlock's position. The court found that the district court's sentence exceeded the statutory maximum and granted the defendant's motion for summary reversal. The appeals court noted that summary disposition was appropriate because "the position of one of the parties is clearly right as a matter of law so that there can be no substantial question."

The original charges against Ashlock involved particularly serious offenses related to child exploitation. Federal law treats possession and receipt of child pornography as distinct crimes, with receipt generally carrying more severe penalties than possession. The statutes under which Ashlock was convicted specifically address cases involving minors under 12 years of age, reflecting federal lawmakers' intent to impose enhanced penalties for crimes involving the youngest victims.

Supervised release violations in child pornography cases often result in imprisonment, as courts view compliance with supervision terms as critical for protecting public safety and preventing recidivism. When defendants violate supervised release conditions, federal judges must balance the need for punishment and deterrence against statutory limitations on their sentencing authority.

The statutory framework governing supervised release revocations, codified in 18 U.S.C. § 3583(e)(3), establishes maximum terms of imprisonment based on the classification of the underlying offense. These limits ensure that revocation sentences remain proportional to the original crimes and prevent district courts from exceeding congressionally mandated sentencing parameters.

This case demonstrates the importance of statutory compliance in federal sentencing, even in cases involving serious offenses like child pornography. While courts have broad discretion in crafting appropriate sentences, they must operate within the boundaries established by federal statutes. The 11th Circuit's decision reinforces that appellate courts will intervene when district courts exceed their statutory authority, regardless of the underlying offense's severity.

The court's decision to grant summary reversal reflects the clear-cut nature of the legal error. Summary disposition procedures allow appellate courts to resolve cases efficiently when the legal issues are straightforward and do not require extensive briefing or oral argument. The fact that the government did not oppose Ashlock's motion suggests federal prosecutors recognized the sentencing error.

Upon remand, the Middle District of Florida will need to resentence Ashlock within the statutory limits for supervised release revocations. The district court will have the opportunity to impose an appropriate sentence on the receipt count that complies with federal law while still reflecting the seriousness of the underlying child pornography offenses.

The case underscores the complex interplay between federal sentencing guidelines, statutory maximums, and judicial discretion in child exploitation cases. While courts seek to impose sentences that adequately punish offenders and protect the public, they must do so within the framework established by Congress.