United States v. Wilkins, No. 17-2258 (8th Cir. 2018)Annotate this Case
Wilkins committed multiple violations of his supervised release, including an assault on his wife. The district court revoked Wilkins’s supervised release and sentenced him to 12 months’ imprisonment with three years’ supervised release, with a condition that prohibited Wilkins from contacting his wife, either directly or indirectly, during the full term of his supervision. The Eighth Circuit affirmed, rejecting an argument that the sentence was substantively unreasonable. District courts have discretion to impose special conditions of supervised release “so long as the conditions are reasonably related to the sentencing factors enumerated in 18 U.S.C. 3553(a), involve no greater deprivation of liberty than is reasonably necessary, and are consistent with the Sentencing Commission’s pertinent policy statements.” Wilkins has a long criminal history and has had numerous violations of supervised release. The court made the appropriate individualized inquiry and concluded that Wilkins “ha[s] a very serious problem with aggression” and that he was “a risk to harm other people, particularly [his] wife.” The court also ordered the probation office to work with Wilkins and his wife to try to set up a method by which the children could have visitation.