United States v. Jonathan López-Díaz — 1st Cir. (Oct 5, 2026)

No. 25-2179 Argued October 5, 2026 Published October 6, 2026

The First Circuit hears United States versus Jonathan Lopez-Diaz. Lopez-Diaz served a prison term for bank robbery and a firearm offense, then came under supervised release in Puerto Rico. Supervised release means a period of supervision after prison, with conditions the person must follow. He completed inpatient drug treatment, then had more positive drug tests. In December 2025, the district court revoked his release and imposed twelve months in prison, with no further supervision. The appeal asks whether drug use was properly treated as felony possession when calculating his violation grade. A violation grade is the severity category used to calculate the recommended prison range. His lawyer will argue that the judge overlooked treatment and less restrictive alternatives. Esteras is a Supreme Court ruling. It bars punishment for the original crime as a reason for discretionary revocation.

United States v. Jonathan López-Díaz (No. 25-2179) — U.S. Court of Appeals for the First Circuit, argued October 5, 2026.

Sources

Argument audio — U.S. Court of Appeals for the First Circuit:https://www.ca1.uscourts.gov/sites/ca1/files/oralargs/25-2179_20261005.mp3

Official argument listing — First Circuit:https://www.ca1.uscourts.gov/doar/results/2026-10

Case background — district court's January 7, 2026 bail-pending-appeal order:https://www.govinfo.gov/content/pkg/USCOURTS-prd-3_13-cr-00204/pdf/USCOURTS-prd-3_13-cr-00204-0.pdf

Supervised release — 18 U.S.C. § 3583:https://www.govinfo.gov/content/pkg/USCODE-2024-title18/pdf/USCODE-2024-title18-partII-chap227-subchapD-sec3583.pdf

Violation grades and sentencing — 2025 Sentencing Guidelines, Chapter 7, Part C:https://www.ussc.gov/guidelines/2025-guidelines-manual/annotated-2025-chapter-7

Esteras v. United States — Supreme Court opinion:https://www.supremecourt.gov/opinions/24pdf/23-7483_6k4c.pdf

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