United States v. St. Clair, No. 18-1933 (7th Cir. 2019)
Annotate this CaseSt. Clair pleaded guilty to unlawful possession of a firearm as a felon. The court notified St. Clair in writing that it proposed to impose six mandatory and 14 discretionary conditions of supervised release. The court later sentenced St. Clair to 33 months in prison and a year of supervised release, including all 20 proposed conditions. St. Clair did not appeal. Within the first month of his supervised release, he started violating the conditions. The government moved to revoke St. Clair’s release, citing 16 violations: using marijuana, failing to submit to drug tests, and not reporting to probation. St. Clair admitted to the violations. The court revoked St. Clair’s supervised release and sentenced him to another year in prison, plus another year-long term of supervision. With no objection from St. Clair, the court included 17 proposed supervised release conditions in the revocation sentence. The Seventh Circuit upheld those conditions, rejecting arguments that the district court failed to justify the discretionary conditions and violated his due process rights by imposing a vague condition based on a superseded version of the Sentencing Guidelines. St. Clair waived his right to challenge his conditions when he acknowledged that he received prior notice of the proposed conditions and discussed them with counsel, and then told the judge that he had no objections or questions.
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