In United States v. Bowers, --- F.4th ---, No. 23-902 (9th Cir. 2025), the Court affirmed the district court’s revocation of Jackson Daniel Bowers’ supervised release in a case in which Bowers argued that Article III, section 2 of the Constitution affords supervisees the right to a jury trial in revocation proceedings held under 18 U.S.C. § 3583(e).
Jackson Daniel Bowers challenges his revocation of supervised release by presenting a novel constitutional argument: that Article III, section 2 of the Constitution affords supervisees the right to a jury trial in revocation proceedings held under 18 U.S.C. § 3583(e). We disagree and find that Article III’s jury trial guarantee is equivalent in scope to the Sixth Amendment’s. As such, Bowers’ Article III claim is foreclosed by circuit precedent, and we affirm the revocation of his supervised release.Current circuit precedent holds that supervisees do not have a right to a jury trial on supervised release proceedings under the Sixth Amendment and we are bound by this precedent. Since Article III’s jury provision and the Sixth Amendment’s are equivalent in scope, it follows that a right not triggered by the Sixth Amendment cannot be independently triggered by Article III. Accordingly, Bowers revocation of supervised release is AFFIRMED.
