United States v. Dodds, No. 19-1135 (7th Cir. 2020)Annotate this Case
Dodds applied for a passport using his brother’s personal information, rather than his own because he was restricted by a condition of probation. He pleaded guilty under 18 U.S.C. 1542. He did not object to any of the proposed supervised-release conditions, which concerned: refraining from excessive alcohol use; remaining within the jurisdiction unless granted permission to leave; permitting a probation officer to visit places including work; submitting to searches of person, property, residence, vehicle, papers, electronic communications, or office upon reasonable suspicion; community service until gainfully employed; not maintaining employment that includes access to personal information; and, as directed by a probation officer, third-party notifications. The court asked, “can [I] impose these conditions without reading them verbatim?”, counsel responded, “yes,” then asked: “Are there any objections ... to any of the proposed conditions of supervised release?”, counsel stated, “No.” Dodds later objected to the search condition. The court rejected his argument, explaining, “the needs for reasonableness and to take into account Mr. Dodds’s privacy while balanced against the need to make sure that Mr. Dodds is not misusing identities or identity documents or engaged in financial wrongdoing, which his history suggests he poses some risk of doing.” Dodds was sentenced to six months in prison and three years’ supervised release. The Seventh Circuit affirmed, rejecting arguments that the challenged conditions were unconstitutionally vague or lacked adequate justification. Dodds waived any objection other than to the search condition.