U.S. v. Canfield

Dist. Ct. erred in imposing certain conditions as terms of supervised release as part of defendant’s sentence upon finding that defendant had violated other previously-imposed terms of supervised release as part of his sentence on charge of possession of child pornography. With respect to condition that defendant inform third-parties of any risk associated with his history of possession of child pornography, Dist. Ct. failed to define with specificity identities or categories of individuals and types of risks to which notification conditions would apply. With respect to condition barring defendant from knowing receipt of any material depicting sexually explicit conduct, Dist. Ct. failed to provide sufficient rationale for said imposition of what otherwise would be legal pornography, where Dist. Ct. merely stated that pornography bar was necessary to assist defendant to successfully complete Sex Offender Treatment Program. Also, Dist. Ct. erred in requiring defendant to participate in substance abuse treatment program, where: (1) defendant admitted to single use of marijuana two years prior to revocation hearing; and (2) record contained no evidence of defendant’s history of substance abuse.