The Ninth Circuit has ruled that an artist and convicted drug distributor was incorrectly denied an early end to his supervised release in order to attend his own art exhibition after a district court used misinterpreted statistics and an outdated judicial manual to justify the restrictions.

A three-judge panel ruled Thursday that Victor Grandy was a "model citizen" following his release from prison and that the court created an impossible situation by upholding the terms of supervised release because Grandy's success proved the restrictions were working.

"Under the current guidance, an individual's success while on supervised release should weigh in favor of early termination — not against it," U.S. Circuit Judge Roopali H. Desai said. "The district court's approach strands individuals like Grandy in a Catch-22: The more they demonstrate their successful reintegration, the less likely they are to obtain early termination of their supervised release."

In 1993, Grandy was convicted of distributing at least 50 grams of crack cocaine and was sentenced to a mandatory minimum life sentence. Grandy and the government jointly asked for a district court to reduce his sentence in 2019 under the First Step Act, according to the opinion.

The district court granted the motion and reduced Grandy's sentence to 360 months, which was reduced to time served after the application of "good time" credit. Grandy was released and began serving a mandatory minimum 10-year supervised release term, the opinion said.

Grandy began a career as a successful artist while on supervised release, gaining an apprenticeship with someone the opinion characterized as a renowned artist. Grandy continued to build his skills, practicing in multiple media including drawing, painting and sculpting, the opinion said.

The opinion also said that Grandy was able to maintain a stable residence and maintain gainful employment and also volunteered at a local food pantry following his release from prison. A Los Angeles gallery discovered Grandy in June 2024 and invited him to present his first solo show as an artist, the opinion said.

Grandy's profile has continued to grow. His artwork is now collected internationally and he regularly has exhibitions across the country. The restrictions from supervised release have prevented him from traveling for his shows, however, the opinion said.

In February 2025, Grandy moved for early termination of his supervised release, arguing that he had shown a successful reintegration into society. The government opposed Grandy's motion, arguing that termination is inappropriate for charges with a mandatory minimum and that the circumstances were not "extraordinary," the opinion said.

A federal district court denied Grandy's motion, finding that it lacked the authority to grant early termination of Grandy's supervised release because the law he was sentenced under had a mandatory minimum. The district court also found that Grandy failed to show that release from the supervised conditions was warranted, the opinion said.

The district court found that because Grandy was demonstrating so much success under supervised release, it should be continued because it was working. The court also cited information not introduced by either party as part of its decision-making process, the opinion said.

The judge introduced a 2022 study from the U.S. Sentencing Commission and an outdated copy of the Administrative Office of the U.S. Courts' Guide to Judiciary Policy, the opinion said. Grandy's appeal argued that the court misinterpreted statistics from the study and that the reference to the judiciary policy guide was an abuse of discretion, the opinion said.

The Ninth Circuit found that the court had misinterpreted the findings in the study, specifically that recidivism statistics cited related only to marijuana traffickers. The court also said the study's finding had no bearing on Grandy because he was convicted of distributing crack cocaine.

The panel also found that the mandatory minimum sentence in the statute used to convict Grandy does not prevent him from being removed from supervised release early. The law used to sentence Grandy is clear that district courts retain discretion in determining whether to end supervised release early, the opinion said.

Grandy was not successful at persuading the panel to reassign his case to a different judge on remand. The panel said there was nothing in the record suggesting that the trial court could not put aside the original decision when hearing the case again on remand, the opinion said.

An attorney representing Grandy and a spokesperson for the U.S. Attorney's Office for the Central District of California did not respond to a request for comment.

U.S. Circuit Judges Ryan D. Nelson and Roopali H. Desai and U.S. District Judge Karen E. Schreier sat on the panel for the Ninth Circuit.

The government is represented by Nicholas Purcell, Iricel E. Payano, Alexander B. Schwab and Bilal A. Essayli of the U.S. Attorney's Office for the Central District of California and Todd Blanche of the U.S. Department of Justice.

Grandy is represented by Alexander Botoman and Cuauhtémoc Ortega of the Federal Public Defender's Office.

The case is United States v. Victor Grandy, case number 25-4491, in the U.S. Court of Appeals for the Ninth Circuit.

--Editing by Rich Mills.