USA v. Howard

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA 	CRIMINAL ACTION
VERSUS 	NO. 23-197
MICHAEL HOWARD, SR. 	SECTION R
ORDER & REASONS
Before the Court is defendant Michael Howard, Sr.’s motion for early
termination of probation. 1 	The Government opposes the motion. 2 	For the
following reasons, the Court denies the motion.
I. 	BACKGROUND
On December 4, 2024, Howard pled guilty to one count of theft of
government 	funds. 	This 	Court 	sentenced 	Howard 	to 	three 	years 	of
probation.3 His term of supervision commenced on April 30, 2025.
In his motion, Howard asks the Court to terminate his probation on
the grounds that he has satisfactorily complied with all its conditions. 4 The
Court considers the motion below.
1 	R. Doc. 52.
2 	R. Doc. 54.
3 	R. Doc. 50.
4 	R. Doc. 512 at 4.
Case 2:23-cr-00197-SSV-DPC Document 56 Filed 10/13/26 Page 1 of 3

2
II. 	LEGAL STANDARD
Under 18 U.S.C. § 3564(c),
[t]he court, after considering the factors set forth in
section 3553(a) to the extent that they are applicable,
may, pursuant to the provisions of the Federal Rules
of Criminal Procedure relating to the modification of
probation, terminate a term of probation ordered
and discharge the defendant . . . at any time after the
expiration of one year of probation, if it is satisfied
that such action is warranted by the conduct of the
defendant and the interest of justice.
The 3553(a) factors include: the nature and circumstances of the offense and
the history and characteristics of the defendant; the need for the sentence to
reflect the seriousness of the offense, promote respect for the law, and
provide just punishment; the need to afford adequate deterrence to criminal
conduct; the need to protect the public from future criminal conduct by the
defendant; and the need to provide the defendant with training and other
correctional treatment. 18 U.S.C. § 3553(a).
III. 	DISCUSSION
Howard has demonstrated compliance with the conditions of his
probation, but such compliance, without more, is insufficient to justify an
early termination of probation. 	Moreover, Howard has paid only slightly
more than $2,000 of the $28,123 he is ordered to pay in restitution. 5
5 	See R. Doc. 54 at 1; R. Doc. 50.
Case 2:23-cr-00197-SSV-DPC Document 56 Filed 10/13/26 Page 2 of 3

3
Considering the 3553(a) factors, Howard’s conduct, and the interests
of 	justice, 	the 	Court 	finds 	that 	an 	early 	termination 	of 	probation 	is
unwarranted. 	The 	Court 	finds 	that 	probation 	remains 	appropriately
imposed and provides the best structure for monitoring Howard’s continued
compliance with his restitution obligations.
IV. 	CONCLUSION
For the foregoing reasons, the Court DENIES Howard’s motion for
early termination of probation.
New Orleans, Louisiana, this _____ day of October, 2026.
_____________________
SARAH S. VANCE
UNITED STATES DISTRICT JUDGE
13th
Case 2:23-cr-00197-SSV-DPC Document 56 Filed 10/13/26 Page 3 of 3