Criminal Sentencing

United States v. Poulin, 809 F.3d 924 (7th Cir. 2016), reh'g denied (Feb. 22, 2016)

Conditions of supervised release were procedurally unreasonable because they were vague and lacked explanation.

Background: After pleading guilty to receipt and possession of child pornography, Matthew Poulin was sentenced to two concurrent 115-month terms of imprisonment and two concurrent life terms of supervised release. Poulin appealed, contending that the district court had erred by not providing reasons for imposing the maximum term of supervised released and that the record lacked justification for the imposition of special conditions (including the requirement of mental health treatment). The Seventh Circuit vacated the original sentence and remanded to the district court for resentencing. On remand, the district court resentenced Poulin to concurrent 84-month terms of imprisonment and a 10-year term of supervised release, including nine standard conditions and seven special conditions. Poulin brought a successive appeal challenging several of the conditions.

Holdings: The Seventh Circuit again vacated the standard conditions of supervised release imposed below, basing its reasoning largely on a line of cases decided after the district court had issued its resentencing judgment. While acknowledging that the district court did not “have the benefit of guidance provided by [the more recent cases],” the Court held that the disputed conditions were not “properly-noticed, supported by adequate findings, and well-tailored to serve the purposes of deterrence, rehabilitation, and protection of the public” (citing United States v. Kappes, 782 F.3d 828 (7th Cir. 2015).

Found in Found in DMHL Volume 35, Issue 1