The U.S. Court of Appeals for the Sixth Circuit affirmed a lower court's revocation of supervised release for Nicholas Javon Martin, who was arrested for domestic violence charges while under federal supervision. The decision, filed Jan. 22, 2026, addresses important questions about due process rights in supervised release revocation proceedings.
Martin was serving supervised release when he was arrested for assault by strangulation and domestic violence, third offense. The charges stemmed from an incident that led to a supervised release revocation hearing in the U.S. District Court for the Western District of Michigan.
At the revocation hearing, the government presented evidence including testimony from Martin's probation officer, police body camera video footage, and photographs related to the alleged assault. Based on this evidence, the district court determined that Martin had violated the terms of his supervised release and imposed an active term of incarceration.
Martin's criminal history dates back to 2017, when he pled guilty to possession with intent to distribute controlled substances and possession of a firearm. Following his conviction, he was sentenced to a term of imprisonment followed by supervised release, during which the domestic violence incident occurred.
On appeal to the Sixth Circuit, Martin challenged the district court's decision on constitutional grounds. Specifically, Martin alleged that the court violated his due process rights by denying him the opportunity to confront and cross-examine witnesses who appeared in the body camera video and claimed he had assaulted the victim.
The confrontation issue is significant in supervised release proceedings, where the rules of evidence are more relaxed than in criminal trials. Martin argued that his constitutional rights were violated when the district court relied on video testimony from witnesses he could not directly cross-examine during the hearing.
However, the Sixth Circuit panel, consisting of Circuit Judges Kethledge, Bush, and Nalbandian, disagreed with Martin's constitutional challenge. Writing for the court, Circuit Judge John K. Bush found that the district court had not violated Martin's due process rights in the revocation proceeding.
The court's opinion addresses the balance between ensuring fair proceedings for defendants facing supervised release revocation and allowing courts sufficient flexibility to determine violations based on available evidence. Supervised release revocation hearings operate under different procedural standards than criminal trials, with courts having broader discretion in considering evidence.
The case highlights the complexities that arise when individuals on federal supervised release face new state criminal charges. The intersection of federal supervision conditions with state-level criminal conduct creates jurisdictional and procedural challenges that courts must navigate while protecting defendants' constitutional rights.
Body camera footage has become increasingly important evidence in criminal and civil proceedings, raising questions about how such evidence should be handled in various legal contexts. The Sixth Circuit's decision provides guidance on the use of video evidence in supervised release proceedings, particularly when live witness testimony may not be available.
The court's affirmance means that Martin's supervised release revocation and resulting incarceration will stand. The decision also reinforces the authority of district courts to revoke supervised release based on evidence of new criminal conduct, even when defendants raise constitutional challenges to the proceedings.
This case reflects broader trends in federal criminal justice, where supervised release violations often involve new criminal conduct at the state level. Courts must balance the goals of federal supervision with practical limitations in gathering and presenting evidence during revocation proceedings.
The opinion was marked as not recommended for publication, indicating that while it resolves the specific dispute between the parties, the court did not view it as establishing broad precedential guidance for future cases. However, the decision still provides insight into how the Sixth Circuit approaches due process challenges in supervised release contexts.
For practitioners handling supervised release cases, the decision emphasizes the importance of understanding the different procedural standards that apply in revocation hearings compared to criminal trials. The ruling suggests that courts have considerable discretion in determining what evidence is sufficient to establish violations of supervised release conditions.
The case also underscores the serious consequences that can result from new criminal conduct during supervised release. Even arrests that do not lead to convictions can provide sufficient basis for revocation proceedings, potentially resulting in additional incarceration time for defendants who believed their federal cases were behind them.