State Recommendations
1. Enhanced Supervision
The State recommends enhanced supervision and periodic compliance review due to the Defendant’s repeated involvement in serious criminal conduct and demonstrated inability to cease unlawful behavior despite prior arrests, convictions, and judicial penalties.
The purpose of enhanced supervision is to encourage accountability, improve compliance with lawful authority, and reduce the likelihood of future criminal activity.
2. Restriction from Government Property
The State recommends that the Defendant be prohibited from entering or remaining upon secured government facilities, law enforcement compounds, correctional facilities, and active government operational scenes unless specifically authorized by Court order or lawful governmental purpose.
This recommendation is directly related to the Defendant’s documented history involving violence toward government employees and law enforcement personnel and is intended to reduce the likelihood of future hostile interactions.
3. Curfew Restrictions
The State recommends the imposition of a nightly curfew during non-business overnight hours except for:
- verified employment,
- medical emergencies,
- legal obligations,
- or prior Court-approved exceptions.
The State submits that structured curfew restrictions are appropriate due to the Defendant’s demonstrated pattern of repeat felony conduct, evasion from law enforcement, and continued criminal activity following prior judicial intervention.
This recommendation is preventative rather than punitive and is intended to reduce opportunities for further criminal conduct while supporting accountability, stability, and behavioral improvement.
Jeremiah Valenti-Sharp
Assistant District Attorney
District Attorney's Office