Memorandum Opinion, Motion for Early Termination of Supervised Release — United States v. Singh (Document 47)

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A Memorandum Opinion filed June 24, 2025 in United States v. Gauravjit Singh, Crim. No. 21-00744 (GC), in the United States District Court, District of New Jersey (Document 47). District Judge Castner denies pro se Defendant Gauravjit Singh's Motion for Early Termination of Supervised Release. The opinion states that Mr. Singh pled guilty on September 22, 2021, to one count of wire fraud under 18 U.S.C. § 1343 and received 46 months of imprisonment followed by three years of supervised release. The Court finds that compliance with release conditions and partial payment of restitution do not warrant early termination, and notes that $934,824.43 in restitution was still owed when the Motion was brought.

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    Case 3:21-cr-00744-GC       Document 47       Filed 06/24/25     Page 1 of 7 PageID: 200




NOT FOR PUBLICATION

                            UNITED STATES DISTRICT COURT
                               DISTRICT OF NEW JERSEY


    UNITED STATES OF AMERICA,

                        Plaintiff,
                                                             Crim. No. 21-00744 (GC)
         v.
                                                           MEMORANDUM OPINION
    GAURAVJIT SINGH,

                        Defendant.


CASTNER, District Judge

        THIS MATTER comes before the Court upon pro se Defendant Gauravjit Singh’s Motion

for Early Termination of Supervised Release. (ECF No. 41.) The Government opposed, and Mr.

Singh replied. (ECF Nos. 44, 45.) The Court has carefully reviewed the parties’ submissions and

decides the matter without oral argument pursuant to Local Criminal Rule 1.1 and Local Civil Rule

78.1(b). For the reasons set forth below, and other good cause shown, Mr. Singh’s Motion is

DENIED.

I.      BACKGROUND

        On September 22, 2021, Mr. Singh pled guilty to one count of wire fraud in violation of 18

U.S.C. § 1343. (ECF No. 33 at 1. 1) The charges against Mr. Singh stemmed from a scheme to

induce individuals to buy personal protective equipment (PPE) during the Covid-19 pandemic,

despite having no intention of actually selling them the PPE. (ECF No. 44 at 4.) The Honorable

Peter G. Sheridan, U.S.D.J. (ret.) sentenced Mr. Singh to a term of imprisonment of 46 months, to


1
       Page numbers for record cites (i.e., “ECF Nos.”) refer to the page numbers stamped by the
Court’s e-filing system and not the internal pagination of the parties.
    Case 3:21-cr-00744-GC         Document 47          Filed 06/24/25   Page 2 of 7 PageID: 201




be followed by three years of supervised release. (ECF No. 33 at 2-3.) Judge Sheridan also

imposed various conditions of supervised release, including requiring Mr. Singh to obtain pre-

approval from the Court or his probation officer before leaving the district in which he resides,

financial disclosures, new debt restrictions, and self-employment disclosures.           (Id.)   Judge

Sheridan ordered Mr. Singh to pay forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.

§ 2461(c) in the amount of $936,160.78, and further ordered Mr. Singh to pay restitution to his

victims in the amount of $936,160.78. (ECF No. 19 at 3; ECF No. 33 at 8.)

           Mr. Singh was released from prison and began serving his term of supervised release on

April 8, 2024. (ECF No. 44.) Mr. Singh filed this Motion just over one year later. (Id.) 2

II.        LEGAL STANDARD

           Courts enjoy broad discretion in deciding whether to grant early termination of supervised

release. See United States v. Melvin, 978 F.3d 49, 52 (3d Cir. 2020). Under 18 U.S.C. § 3585

(e)(1), a court may terminate a term of supervised release “at any time after the expiration of one

year of supervised release . . . if it is satisfied that such action is warranted by the conduct of the

defendant released and [in] the interest of justice.” In determining whether the defendant’s conduct

and the interest of justice warrant the relief sought, courts must consider the following sentencing

factors:

                  (1) the nature and circumstances of the offense and the defendant’s
                  history and characteristics;

                  (2) the need to afford adequate deterrence to criminal conduct,
                  protect the public from further crimes of the defendant, and provide
                  him with needed educational or vocational training, medical care, or
                  other correctional treatment in the most effective manner;




2
           This matter was reassigned to the Undersigned on January 23, 2025. (ECF No. 37.)

                                                   2
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               (3) the kinds of sentence and sentencing range established for the
               defendant’s crimes;

               (4) pertinent policy statements issued by the United States
               Sentencing Commission;

               (5) the need to avoid unwarranted sentence disparities among
               defendants with similar records who have been found guilty of
               similar conduct; and

               (6) the need to provide restitution to any victims of the offense.

Melvin, 978 F.2d at 52 (citing 18 U.S.C. § 3553(a)(1), (2)(B)-(D), (4)-(7)).

       District courts need not “make specific findings of fact with respect to each of the factors,”

nor must they find that extraordinary or changed circumstances exist to grant a defendant’s request

for early termination of supervised release. Id. at 52-53. However, early termination of supervised

release will generally “be proper only when the sentencing judge is satisfied that new or unforeseen

circumstances warrant it” because § 3553(a) requires that sentences be “sufficient, but not greater

than necessary when first pronounced.” Id. at 53 (internal citations and quotation marks omitted);

see also United States v. Szymanski, Cr. No. 12-247, 2020 WL 6515958, at *2 (W.D. Pa. Nov. 5,

2020) (“The court explained in Melvin that, although not required, some changed circumstances

will generally be important to warrant early termination of supervised release[.]”).

III.   DISCUSSION

       Mr. Singh argues that his supervised release should be terminated early for the following

reasons: (1) he has thus far satisfied every condition of his supervised release; (2) his father’s

stroke constitutes a new and unforeseen circumstance; (3) his actions leading to his conviction

were an “aberration”; (4) he has already paid over $1.2 million in restitution and has obtained a

$507,000 judgment that will be applied towards his outstanding fees; (5) he can “pursue additional

income opportunities to accelerate repayment” if he is granted early termination; (6) his probation

officer recommended that he apply for early termination; and (7) “the goals of supervised released-

                                                 3
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—deterrence, rehabilitation, protection of the public, and reintegration—have been fully

achieved.” (ECF No. 41.)

       Although the Government “appreciates Singh’s apparent compliance” with the conditions

of his supervised release, it opposes early termination. (See ECF No. 44.) The Government

contends that: (1) “simply complying with the terms of a sentence does not merit a reduction of

that sentence”; (2) Mr. Singh’s crimes, especially against the backdrop of the Covid-19 pandemic,

were “egregious,” and he lacked remorse because he allegedly participated in additional fraud

unrelated to his PPE crimes while awaiting sentencing; (3) the special conditions imposed

“intended to monitor the specific conduct Singh now wishes to pursue—unfettered entrepreneurial

business activities”; (4) there are no extraordinary circumstances that warrant release; (5) Mr.

Singh still owes the entire forfeiture amount and essentially the entire restitution amount; and (6)

Mr. Singh’s probation officer takes no position on his application and did not encourage him to

file this motion. (ECF No. 44.) Mr. Singh replied arguing that the Government ignored his father’s

stroke and the money he already paid in restitution. (ECF No. 45.)

       The Court has considered the § 3553(a) factors and finds that early termination of

supervised release is neither warranted nor in the interest of justice. While the Court commends

Mr. Singh’s compliance with the conditions of his supervised release, compliance is exactly what

is expected of him. Courts have routinely found that compliance with the terms of supervised

release is not enough to succeed on a motion for early termination of supervised release. See

United States v. Desu, Cr. No. 18-613, 2024 WL 3878748, at *3 (D.N.J. Aug. 20, 2024)

(“[C]ompliance with the terms of supervised release is what is expected of probationers, and

without more, cannot justify early termination.” (citing United States v. Caruso, 241 F. Supp. 2d

466, 469 (D.N.J. 2003))); United States v. Amato, Cr. No. 18-561, 2024 WL 3850384, at *3 (D.N.J.



                                                 4
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Aug. 16, 2024) (same); United States v. Rosendary, Cr. No. 22-00742, 2024 WL 619574, at *3

(D.N.J. Feb. 14, 2024) (“[The defendant’s] compliance with the terms of supervision is expected

and not enough to justify early termination.”); United States v. Jaime, Cr. No. 05-34, 2013 WL

4434909, at *1 (W.D. Pa. Aug. 16, 2013) (“[I]t is axiomatic that ‘full compliance with all of the

conditions of supervised release does not warrant early termination.’”) (citation omitted). Early

termination based on compliance is particularly inappropriate here, as Mr. Singh has served just

over one third of his term of supervised release. See United States v. Santiago, Cr. No. 12-566,

2024 WL 2092035, at *6 (E.D.P.A. May 9, 2024) (“[G]iven that [the defendant] is seeking to

terminate supervised release after only reaching the halfway point of his supervision, the Court

does not find that his commendable conduct warrants early termination of his supervision.”).

Accordingly, the Court finds that Mr. Singh’s compliance with the terms of his supervised release

is insufficient to justify early termination.

        Likewise, the Court finds that Mr. Singh’s payment of a portion of the restitution amount

does not warrant early termination. While the Court appreciates Mr. Singh’s continued efforts

toward making his victims whole, payment of restitution and forfeiture are expected of Mr. Singh.

Further, at the time of bringing his Motion, Mr. Singh still owed $934,824.43 in restitution to his

victims and $936,160.78 in forfeiture to the United States, (ECF No. 44 at 1), which weighs against

granting early termination. 3 See United States v. Stiso, Cr. No. 14-484, 2021 WL 1291648, at *3

(D.N.J. Apr. 6, 2021) (“[T]he [c]ourt finds that serving the remainder of [the defendant’s]

supervised release term is necessary to ensure [the d]efendant continues to make payments toward



3
       Mr. Singh disputes this is the actual amount due, as he claims he has obtained a judgment
of $507,000 against another “bad actor involved in this case” that “is being applied to his restitution
balance.” (ECF No. 45 at 1.) But even accepting that as true, Mr. Singh would still owe over $1.3
million.

                                                  5
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the nearly $400,000 restitution balance outstanding.”); United States v. Boyle, Cr. No. 15-271,

2023 WL 2601176, at *2 (E.D. Pa. Mar. 22, 2023) (denying early termination of supervised release

due in part to the defendant’s outstanding restitution balance). 4

        Further, Mr. Singh contends that his father’s stroke is a new and unforeseen circumstance

that should justify early termination. Mr. Singh submits that due to his father’s stroke, his father

can no longer run the “family-owned travel business” and that his “family—including [his] mother,

and sister—now depends entirely” on the business. (ECF No. 41 at 2.) The terms of Mr. Singh’s

supervised release require Court approval for travel, and Mr. Singh asserts that he cannot

effectively manage the company without the ability to “travel internationally on short notice.” (Id.)

While the Court is sympathetic to Mr. Singh’s situation, this unfortunate development does not

warrant early termination of Mr. Singh’s supervised release. Mr. Singh provides no details about

his family’s travel business, nor does he explain why international travel on such short notice is

required.   Moreover, Mr. Singh does not explain why his mother or sister cannot travel

internationally to support the business.

        In any event, it is clear that Mr. Singh’s travel restrictions do not hinder his ability to

maintain employment, as he is currently employed full-time as an acquisitions manager. (ECF No.

41 at 1.) See United States v. Wood, Cr. No. 16-271, 2022 WL 2916069, at *2 (D.N.J. July 25,

2022) (denying early termination where the pilot-defendant sought early termination to pursue a

position with a higher income that required international travel, reasoning that “[the defendant’s]

current employer has not presented [the inability to travel internationally] as being an issue”). Mr.


4
         In support of his Motion, Mr. Singh cites to “United States v. Harris, No. 04-CR-44, 2020
WL 2615760 (D.N.J. May 22, 2020).” Mr. Singh claims that the court there “granted early
termination even where restitution remained outstanding, finding that rehabilitation and good-faith
efforts toward repayment were sufficient.” (ECF No. 41 at 2.) The Court has been unable to locate
this case.

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