The U.S. Court of Appeals for the Third Circuit affirmed a district court's determination that Thomas Clay Wade violated the conditions of his supervised release, rejecting his appeal in a non-precedential opinion filed Jan. 12, 2026.

Wade, who was originally convicted of federal firearms and drug violations, had been sentenced to 240 months in prison followed by six years of supervised release. His supervised release conditions included requirements that he commit no federal, state, or local crimes and that he not unlawfully possess or use controlled substances.

The violation proceedings arose after Wade's then-girlfriend accused him of assault while he was serving his supervised release term. According to court documents, the victim was discovered in distress outside a nursing home, leading to the supervised release violation allegations.

In his appeal, Wade challenged the district court's finding that he violated his supervised release conditions. The primary issue before the Third Circuit panel was whether good cause existed for admitting out-of-court statements that formed the basis for the violation finding.

The Third Circuit panel concluded that the district court properly admitted the out-of-court statements after finding good cause existed under Federal Rule of Criminal Procedure 32.1(b)(2)(C). The court noted that supervised release violation proceedings have more relaxed evidentiary standards than criminal trials, allowing for the admission of reliable hearsay evidence when good cause is shown.

The panel emphasized that the district court conducted a thorough analysis of the circumstances surrounding the statements and properly weighed their reliability against Wade's confrontation rights. The court found that the statements bore sufficient indicia of reliability to support their admission in the violation proceeding.

This non-precedential decision reinforces the established principle that district courts have significant discretion in evidentiary determinations during supervised release violation proceedings, while maintaining appropriate safeguards for defendants' rights.