United States v. Sterling, No. 19-1711 (8th Cir. 2020)
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After the United States Probation Office petitioned the district court for modification of defendant's sentence to add three special conditions of supervised release, he appealed the grant of the petition.
The Eighth Circuit held that the district court did not abuse its discretion in allowing defendant to proceed pro se at the modification hearing. The court affirmed the imposition of the mental health assessment condition and the search condition. However, the court vacated the financial disclosures condition as vague and overbroad. In this case, the government failed to tailor the proposed special condition to the employment circumstances that warranted modification of Standard Condition 5 and thus imposed an overbroad special condition that imposes a greater deprivation of liberty than is reasonably necessary and is not the minimum extent necessary to protect the public.
Court Description: [Loken, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Criminal case - Sentencing. The district court did not err in allowing defendant to proceed pro se on the hearing to modify the conditions of his supervised release; the court did not err in granting the Probation Office's motion to add two special conditions of supervised release; based on testimony regarding defendant's current mental conditions, it was not error to require a mental health assessment be performed; nor did the court err in imposing a search condition based on reasonable suspicion; the court erred, however,in requiring defendant to provide the probation office with access to any business record or financial information, as the condition is vague and overbroad and is not warranted by the circumstances; the condition is vacated.
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