United States v. Brown, No. 14-3305 (8th Cir. 2015)
Annotate this CaseBrown pled guilty to being a felon in possession of a firearm, 18 U.S.C. 922(g)(1) and 924(a)(2). The district court sentenced Brown to 57 months imprisonment, recommending “the defendant participate in the Bureau of Prisons’ 500-Hour Comprehensive Residential Drug Abuse Treatment Program.” The district court also sentenced Brown to three years of supervised release with several special conditions of supervision, including: The defendant must not use alcohol nor enter bars, taverns, or other establishments whose primary source of income is derived from the sale of alcohol. Brown admitted to marijuana use twice in his life—both times while on parole in 2014—and alcohol use once in his life, in December 2013. Brown’s criminal history involved no charges relating to drugs or alcohol. Brown’s PSR indicated he never participated in substance-abuse treatment, but also reported Brown stated he “may benefit” from such a course of treatment. The court overruled Brown’s objection to the alcohol special condition. The Eighth Circuit vacated the condition. The district court did not “‘make sufficient findings on the record so as to ensure that the special condition satisfies the statutory requirements.”
Court Description: Per Curiam - Before Riley, Chief Judge, and Murphy and Melloy, Circuit Judges] Criminal case - Sentencing. The district court did not make sufficient findings on the record to ensure that the special condition it imposed regarding alcohol satisfies the statutory requirements of 18 U.S.C. Sec. 3553 and Sec. 3583; the imposition of the condition was an abuse of discretion and is vacated. See U.S. v. Woodall, 782 F.3d 383 (8th Cir. 2015).
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