United States v. Thompson, No. 10-3840 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of receipt and distribution of child pornography and sentenced to 60 months imprisonment followed by 5 years of supervised release. On appeal, defendant claimed that the district court erred in imposing certain special conditions of supervised release. The court held that the district court did not abuse its discretion in imposing Special Conditions 8, 9, and 10 where the record supported the district court's finding that restricting defendant's interaction with minors was reasonably necessary for the purposes set forth in 18 U.S.C. 3553(a) and where these special conditions did not impose a greater deprivation of liberty than was reasonably necessary because they were not complete prohibitions on defendant's interaction with minors. The court also held that because no affirmative indication occurred in this case, Special Condition 13, 14, and 15 did not constitute an impermissible delegation of judicial authority. The court held however, that the district court erred when it failed to make individualized findings on the record to support the imposition of Special Condition 16, but the error was harmless where other evidence on the record provided ample support for the imposition of the special condition. The court also held that Special Condition 16 was not unconstitutionally overbroad or unconstitutionally vague. The court further held that, in light of the sound reasons announced by the district court for imposing Special Conditions 17 and 18, and without any clear objection from defendant, the imposition of these special conditions was not an abuse of discretion. Accordingly, the court affirmed defendant's sentence.
Court Description: Criminal case - Sentencing. In a conviction involving receipt and distribution of child pornography, the district court did not err in imposing special conditions in defendant's supervised release which restricted his interaction with minors, dealt with potential sex-offender treatment and polygraph testing, and required probation approval of his employment and residence changes, as the conditions were reasonably related to his offense or protection of the public and did not constitute impermissible delegation of judicial authority; while the district court erred in imposing restrictions on possession of pornography without making individualized findings, the reasons for the condition were apparent from the record, and the error in failing to make the required findings was harmless; nor was the restriction unconstitutionally overbroad.
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