Revocation of probation is within the discretion of the district court. See United States v. Rife, 835 F.2d 154, 156 (7th Cir. 1987). "The district court's discretion does, however, have limitations, and we have authority to review revocation decisions for fundamental unfairness or for an abuse of discretion."

We disagree. In U.S. v. Rife, 835 F.2d 154 (7th Cir. 1987), the defendant pled guilty to the charge of unlawful possession of food stamps and was placed on probation. During her probationary period, the defendant told her probation officer that she had frequently delivered marijuana to her imprisoned husband. The defendant's probation was subsequently revoked on that foundation and the defendant was sentenced to three years in prison for her original offense.

We will not reverse the court's decision absent an abuse of discretion. United States v. Rife, 835 F.2d 154, 155 (7th Cir. 1987). This standard of review is considerably lower than the standard applied in Illinois criminal cases.

This language might lead to seemingly harsh results, but it is consistent with the broad discretion which is traditionally given to district courts to revoke probation when probation conditions are violated. United States v. Morin, 889 F.2d 328, 331 (1st Cir. 1989); United States v. Holland, 874 F.2d 1470, 1473 (11th Cir. 1989); United States v. Rife, 835 F.2d 154, 156 (7th Cir. 1987); United States v. Simmons, 812 F.2d 561, 565 (9th Cir. 1987); United States v. Babich, 785 F.2d 415, 418 (3d Cir.), cert. denied, 479 U.S. 833, 107 S.Ct. 123, 93 L.Ed.2d 69 (1986); United States v. Young, 756 F.2d 64, 65 (8th Cir. 1985). Indeed, a court can revoke probation when it is reasonably satisfied that the probation conditions have been violated, without the government being required to present proof beyond a reasonable doubt that the defendant committed the alleged acts.

The district court does not have to be convinced beyond reasonable doubt, but instead must only be reasonably satisfied, that the probationer has failed to comply with the probationary conditions. See United States v. Rife, 835 F.2d 154, 156 (7th Cir. 1987); United States v. Nagelberg, 413 F.2d 708, 709-10 (2d Cir. 1969), cert. denied, 396 U.S. 1010, 90 S.Ct. 569, 24 L.Ed.2d 502 (1970). On appeal we will reverse the district court's finding of a violation of probation only if the district court has abused its discretion.

United States v. Neyens, 831 F.2d 156, 160 (7th Cir. 1987). As we stated in United States v. Rife, 835 F.2d 154, 156 (7th Cir. 1987): "This court will not question the relative importance placed on one factor over another." See also Sato, 814 F.2d at 452.

Shortly afterward, without citing Yancey, we reiterated the "reasonably satisfied" standard, even remarking that "the district court went further than necessary when it evaluated the evidence before it under a preponderance-of-the-evidence standard." United States v. Warner, 830 F.2d 651, 655 (7th Cir. 1987); see also United States v. Rife, 835 F.2d 154, 155 (7th Cir. 1987). The district court applied the "reasonably satisfied" standard in this case, not the preponderance standard.

Additionally, case law holds that revocation of supervised release or probation is appropriate regardless of whether a defendant has the willful intent to violate the conditions. United States v. Briggs, 42 Fed.Appx 898, 2002 WL 1778311 (S.D.Cal. 2002) See also United States v. Rife, 835 F.2d 154, (7th Cir. 1987), where the court rejected defendant's argument that because she acted under pressure and duress, she did not form the requisite mental state to commit a crime and thereby violate her conditions of probation. Even if the absence of intent could excuse Defendant's supervised release violation, the Federal Competency Evaluation Report prepared by Dr. Sora amply supports a finding that the Defendant was capable of forming the requisite intent both at the time he was evaluated in March of 2008 and at the time he committed the new offense on August 28, 2007. Because actual notice is not required when violation of a condition entails a new criminal act and because revocation is appropriate regardless of whether a defendant has the willful intent to violate the conditions, the Defendant's mental state at the time he was advised he was on supervised release (June 8, 2006) is irrelevant.