United States v. Carson, No. 17-3589 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to the receipt, possession, and attempted distribution of child pornography. The court held that the district court did not procedurally err by imposing a life term of supervised release, because the district court considered the 18 U.S.C. 3553(a) factors to both defendant's terms of imprisonment and supervised release. Furthermore, the district court's brief explanation of defendant's sentence, including the term of supervised release, was not plainly erroneous.
The court also affirmed the special conditions of supervised release, holding that the prohibition on possessing pornographic materials, restrictions on possession of a computer or like device, and restrictions on creation of a social media account on sites which allow access by minors or exchange of sexually-explicit materials did not result in greater deprivation of liberty than reasonably necessary. Although the district court plainly erred by failing to make any effort to support the challenged conditions (or any other special condition) with individualized findings, the reasons for the challenged conditions were sufficiently evident from this record.
Court Description: Grasz, Author,with Gruender and Kelly, Circuit Judges] Criminal case - Sentencing. In this child pornography case, the district court did not plainly err in imposing a lifetime term of supervised release; since supervision is a part of a defendant's sentence, the district court's evaluation of the 3553(a) factors also satisfied its obligations under 3553(c), and the court did not need to provide a separate analysis for the supervision portion of the sentence; no error in imposing three special conditions as part of defendant's supervised release - prohibition on possessing pornographic materials; restrictions on possession of a computer or like device; and restrictions on creation of a social media account on sites which allow access by minors or exchange of sexually-explicit materials - as none of the conditions resulted in a greater deprivation of liberty than reasonably necessary; while the district court plainly erred by failing to make individualized findings to support the conditions, reversal is not required as the reasons for the conditions were sufficiently evident from the record. Judge Grasz, concurring. Judge Kelly, dissenting.
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