United States v. Carson

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. View "United States v. Carson" on Justia Law