United States v. Phillips, No. 14-2118 (8th Cir. 2015)
Annotate this CaseIn 2001, Phillips pled guilty to statutory rape. In 2012, he failed to register as a sex offender and was sentenced to 24 months’ imprisonment and 10 years’ supervised release. In 2014, two months into his release, the Probation Office moved to revoke supervision. Phillips admitted violating release conditions, including unsupervised contact with minors. The court sentenced him to 24 months’ imprisonment and supervision for life. As a special release condition, Phillips cannot “possess or use . . . a computer . . . gaming equipment, cellular devices, or any other device with access to any ‘on line computer services,’ or subscribe to or use any Internet service . . . without the written approval of the probation office.” The Eight Circuit affirmed the lifetime supervision, vacated the special condition, and remanded. Phillips made no legal argument rebutting the presumptive reasonableness of lifetime supervision. Because the possibility of possessing child pornography may not necessarily justify a broad ban on Internet access, Phillips only possessed adult pornography. On remand, lesser restrictions on Phillips’s Internet access may be consistent with 18 U.S.C. 3583(d).
Court Description: Benton, Author, with Smith and Shepherd, Circuit Judges] Criminal case - Sentencing. The district court did not abuse its discretion in imposing lifetime supervision; however, the court erred in imposing a special condition of supervision restricting defendant's Internet access on the basis of the record before it, and the matter is remanded for further proceedings.
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