United States v. Aaron Martinez
23-10757
| 11th Cir. | Sep 20, 2024Background:
- Aaron Martinez was sentenced to 248 months' imprisonment and 5 years of supervised release for drug and firearm offenses.
- At his sentencing hearing, the district court did not orally pronounce 16 discretionary conditions of supervised release.
- The written final judgment included these discretionary conditions for the first time.
- These conditions were not referenced during sentencing, nor was the related administrative order mentioned.
- Martinez argued that he was denied due process by not being given notice or an opportunity to object to these conditions.
- The appellate court reviewed the due process argument de novo, as Martinez had no earlier chance to object.
Issues:
| Issue | Martinez's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether imposing unannounced supervised release conditions in the written judgment violates due process | Imposing conditions without mentioning them at sentencing deprived him of due process | Conditions were standard or rooted in administrative order | Imposing conditions not pronounced at sentencing violated due process; judgment vacated and remanded |
Key Cases Cited
- United States v. Etienne, 102 F.4th 1139 (11th Cir. 2024) (plain error review applies to issues not raised below)
- United States v. Bull, 214 F.3d 1275 (11th Cir. 2000) (de novo review where defendant had no prior opportunity to object)
- United States v. Rodriguez, 75 F.4th 1231 (11th Cir. 2023) (discretionary supervised release conditions must be pronounced at sentencing)