United States v. LeCompte, No. 14-2200 (10th Cir. 2015)
Annotate this CaseIn 2003, Paul LeCompte pled guilty in state court to a sex offense involving a minor female and was required to register as a sex offender. In 2010, after having traveled in interstate commerce, LeCompte failed to register. In 2011, he pled guilty in federal court to failing to register under the Sex Offender Registration and Notification Act ("SORNA"). As part of the sentence on this conviction, the district court imposed several conditions, including one prohibiting any association with minors except in the presence of an adult approved by the U.S. Probation Office ("Probation"). In 2014, a probation officer visited LeCompte's home and found him sitting outside with several adults (none of them approved by Probation) and his then-girlfriend's three-year-old granddaughter. Because LeCompte had associated with a minor in the absence of an approved adult, Probation filed a petition to revoke LeCompte's supervised release. LeCompte moved to dismiss, challenging the supervised release condition as applied. The district court denied his motion, revoked his supervised release, and sentenced LeCompte to a prison term. It also imposed six standard sex offender conditions. LeCompte appeals the district court's denial of his motion to dismiss. He also challenged the procedural and substantive reasonableness of the six sex offender conditions imposed. Upon review, the Tenth circuit concluded the district court's as-applied analysis was inadequate and incomplete. The denial of the motion to dismiss was reversed and the case remanded for further consideration.
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