United States v. Angel Ivostraza-Torres, 16-4442

Background

Angel Catalino Ivostraza-Torres pleaded guilty to possession with intent to distribute ≥500g of cocaine and was sentenced to 204 months imprisonment and 8 years supervised release.
He was designated a career offender, which produced a Guidelines range of 262–327 months; the court granted a downward variance to 204 months.
The District Court orally imposed standard supervised-release conditions and filed the AO form listing thirteen standard conditions; Standard Condition 4 included the language that the defendant will “support his or her dependents and meet other family responsibilities.”
The AO had updated the standard form about a month before sentencing to remove that language, and the Seventh Circuit had held similar language vague and overbroad.
Ivostraza-Torres appealed, arguing the inclusion of the impermissible language required vacatur and full resentencing so the court could reconsider the prison term in light of a proper financial-support condition.
The Government conceded the condition was error and sought a limited remand to remove the offending language; the Third Circuit agreed a limited remand was appropriate.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the inclusion of “meet other family responsibilities” in Standard Condition 4 requires vacatur and full resentencing	Ivostraza‑Torres: the impermissible condition is vague/overbroad and may have affected the overall sentence; remand for full resentencing needed to permit a meaningful financial-support condition	Government: concession that the language was erroneous but argues only a limited remand to correct the form condition is necessary	Court: limited remand ordering deletion of the offending language; full de novo resentencing not warranted
Whether erroneous supervised‑release language here altered offense level, Guidelines range, or sentence	Ivostraza‑Torres: cross‑cutting effects between supervised‑release conditions and prison term could justify reconsideration of sentence	Government: no plausible effect on offense level, Guidelines, or term of imprisonment	Court: no record showing any effect; sentence remains intact
Standard for remand when supervised‑release condition is facially invalid	Ivostraza‑Torres: urges broader (Seventh Circuit) standard that possible reconsideration merits full resentencing	Government: follow Third Circuit practice of limited remand to reformulate/eliminate defective conditions	Court: adopts limited‑remand approach consistent with Third Circuit precedents
Whether resentencing is required under Ciavarella when a sentencing error concerns supervised‑release conditions	Ivostraza‑Torres: argues Ciavarella supports de novo resentencing	Government: Ciavarella applies when vacation affects offense level/Guidelines/aggregate sentence, not isolated supervised‑release wording	Court: Ciavarella standard not met; no de novo resentencing required

Key Cases Cited

United States v. Guidry, 817 F.3d 997 (7th Cir.) (concerning vagueness/overbreadth of family‑support language in standard condition)
United States v. Albertson, 645 F.3d 191 (3d Cir. 2011) (discussing interplay of supervised‑release conditions and prison term)
United States v. Ciavarella, 716 F.3d 705 (3d Cir. 2013) (de novo resentencing required when vacation affects offense level, Guidelines range, or aggregate sentence)
United States v. Miller, 594 F.3d 172 (3d Cir. 2010) (remand to district court to eliminate or reformulate erroneous supervised‑release conditions)
United States v. Thompson, 777 F.3d 368 (7th Cir. 2015) (Seventh Circuit standard advocating resentencing when reconsideration of a condition may conceivably induce a change in prison sentence)
United States v. Anglin, 846 F.3d 954 (7th Cir. 2017) (ordered limited remand to clarify supervised‑release conditions)
United States v. Wilson, 413 F.3d 382 (3d Cir. 2005) (Department of Justice policies do not create enforceable rights for defendants)