Allen v. State, 141 A.3d 194

Troy Robert Allen was convicted of sexual abuse of a minor household member and related sex and assault offenses for molesting a ten‑year‑old girl (B.) who lived in his home; he also had an infant son (F.) in the household.
A DHMH mental health assessment diagnosed exhibitionist disorder, found poor insight, and assessed a moderate-to-elevated risk of sexual reoffending; a PSI noted other pending charges and recommended no unsupervised contact with minor females.
At sentencing the court imposed a partially suspended 25‑year sentence for the sexual‑abuse count and five years of supervised probation after release, conditioned on no unsupervised contact with minors (including his son) for the probation term.
Allen appealed, arguing the no‑unsupervised‑contact condition unreasonably infringed his fundamental parental due‑process right because the record contained no evidence he posed a danger to his biological son.
The Court of Special Appeals upheld the condition as reasonably related to the offense; the Maryland Court of Appeals granted certiorari and affirmed, holding the probation condition was reasonable and rationally related to the crime and protection of children.

Issue	Allen's Argument	State's Argument	Held
Whether a probation condition prohibiting unsupervised contact with minors (including the defendant's son) is unreasonable and violates the parental due‑process right	Condition unlawfully infringes Allen's fundamental right to parent because record lacked evidence he was a danger to his son; heightened scrutiny required	Condition is reasonably related to protecting minors and preventing recidivism given convicting conduct, mental‑health findings, and risk of "crossover"; condition is narrow and time‑limited	Court affirmed: Maryland applies the usual reasonableness/rational‑relation test for probation conditions; the no‑unsupervised‑contact condition was reasonably related to the offense and protection of children and was not an abuse of discretion

Meyer v. State, 445 Md. 648 (discussing limits on probation conditions and the reasonableness/rational‑relation requirement)
Henson v. State, 212 Md. App. 314 (Md. Ct. Spec. App.) (upholding probation condition that affected fundamental rights where condition was reasonably related to offense and rehabilitation)
United States v. Lonjose, 663 F.3d 1292 (10th Cir.) (federal supervised‑release decisions applying heightened scrutiny where restrictions affect parental rights)
State v. Strickland, 169 N.C. App. 193 (upholding a probation condition barring residence with minors despite victim differing by gender/relationship; rejecting requirement to tailor conditions to offender's specific victim preferences)