United States v. Brown, No. 18-2644 (7th Cir. 2019)
Annotate this CaseBrown pled guilty to distributing a controlled substance. Thornton pled guilty to bank robbery and an associated firearms charge. The same district court separately imposed terms of imprisonment followed by supervised release on both. The court imposed mandatory conditions under 18 U.S.C. 3583(d) and U.S.S.G. 5D1.3(a) (do not commit another crime, do not possess a controlled substance, submit to drug testing, and submit a DNA sample). There were also special (discretionary) conditions, authorized by 18 U.S.C. 3553(a), 3583(d). The PSRs also contained nine “administrative” run-of-the-mill conditions that often accompany supervised release, including a requirement to report to the probation office following release from prison, a prohibition on possessing firearms, a direction not to leave the judicial district without permission, and a requirement to communicate with the probation office. The PSRs cited no authority for these conditions but stated that the conditions are administrative and applicable whenever supervision is imposed, regardless of the substantive conditions. Brown and Thornton argued that the PSRs suggested the conditions are mandatory, but there is no statutory basis for that proposition, and that the imposition of administrative conditions violated their due process rights. The Seventh Circuit affirmed, noting that neither defendant objected to the conditions in the district court, and so both waived the issue.
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