Does United States v. Haymond Impact Probation and Post-Release Supervision in North Carolina?

In United States v. Haymond, 139 S. Ct. 2369 (2019), a divided Supreme Court concluded that a federal statute was unconstitutional to the extent that it exposed the defendant to additional mandatory imprisonment based on a judicial finding that he had violated his supervised release. Does the case have implications for probation and post-release supervision hearings in North Carolina? In Haymond, the defendant was convicted of possession of child pornography—a crime punishable by up to 10 years in prison under federal law—and sentenced to 38 months of imprisonment followed by 10 years of supervised release. Supervised release is term of community supervision somewhat similar to post-release supervision in North Carolina’s state system. While on supervised release, he “encountered trouble,” slip op. at 2, when government officers found apparent child pornography on his computer and cellphone and sought revocation of his supervised release. A judge holding a supervised release violation hearing ordinarily would have discretion to revoke supervised release and order a defendant reimprisoned for a period up to a maximum period set by statute. 18 U.S.C. § 3583(e)(3). That period typically would have been two years in Mr. Haymond’s case. However, Haymond was subject to a separate supervised release rule that applies to certain sex offenders. That rule, codified in 18 U.S.C. § 3583(k), says a judge must revoke supervised release and must impose additional imprisonment of at least 5 years and up to life for covered supervisees who violate their conditions of release by committing certain enumerated offenses (including possession [...]