Failure to Address Objections to SR Conditions – Even “Standard” Ones – Unreasonable

US v. Boyd: Boyd pleaded guilty to being a felon in possession of a firearm. In the Presentence Investigation Report, the probation officer referred to a list of “standard” conditions that applied in the district “unless affirmatively omitted by the presiding judge.” Boyd objected to several of them, including those covering a work requirement, associating with felons, and sharing financial information with probation. At sentencing, the court imposed all of the challenged conditions, because they were “standard” in the district. Boyd also objected to another condition, involving warrantless searches, which the district court overruled, again by referencing the “standard” conditions.

On appeal, the Fourth Circuit vacated Boyd’s sentence as being procedurally unreasonable. After disposing with the Government’s argument that Boyd had not sufficiently preserved the issue of the challenged conditions (by not renewing an objection at sentencing, having objected to the PSR), the court applied the now familiar law that a district court must sufficiently explain its sentencing decisions, including the imposition of conditions of supervised release. That requirement cannot be satisfied merely by citing to a list of “standard” conditions adopted in the district. Regardless of how routine the case may be, where the defendant makes non-frivolous objections to the proposed conditions, the district court must address them.

Congrats to the Defender office in Western NC on the win!