United States v. Castillo, 20-11243

Raymond Castillo pleaded guilty to being a felon in possession of a firearm and was sentenced to 21 months imprisonment and three years of supervised release.
The district court imposed a special condition of supervised release requiring participation in sex‑offender treatment.
Castillo has a 1999 juvenile adjudication for aggravated sexual assault, subsequent probation revocations, a history of treatment, and a conviction for failure to register as a sex offender—facts reflected in the presentence report (PSR).
Castillo challenged the sex‑offender‑treatment condition on appeal, arguing it was not reasonably related to his offense and raising due‑process/ineffective‑assistance arguments about the timing of the juvenile adjudication.
The government relied on the PSR and its written response (which included Castillo’s history of abuse) to support the condition; the district court referenced the response but the record shows the court relied on Castillo’s overall history and characteristics.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sex‑offender‑treatment SR condition was an abuse of discretion	Condition is reasonably related to §3553(a) factors given Castillo’s sexual‑offense history and need for deterrence/public protection	Condition unrelated to the §922(g) conviction and improperly based on remote juvenile adjudication	Affirmed: condition reasonably related to history/characteristics and sentencing goals
Whether Castillo could litigate due‑process/ineffective‑assistance challenges to the timing of a 1999 juvenile adjudication at sentencing	Such challenges are not properly entertained at sentencing	Castillo asserted timing raised due‑process and counsel‑ineffectiveness issues	District court may not entertain that challenge at sentencing
Whether the PSR sufficiently documented the facts supporting the special condition	PSR documented prior sexual adjudication, probation revocations, treatment history, and failure to register	Castillo argued the PSR was insufficient support for the condition	PSR was sufficient to support the condition
Whether the district court improperly relied primarily on the government’s written response (history of abuse)	Government: court cited response but relied on defendant’s total history	Castillo: court relied chiefly on the abuse history outside the record	Court did not rely primarily on that response; relied on overall history/characteristics

United States v. Caravayo, 809 F.3d 269 (5th Cir.) (standard: review of SR conditions for abuse of discretion)
United States v. Fernandez, 776 F.3d 344 (5th Cir.) (§3583(d) limits and §3553(a) relationship requirement)
United States v. Iverson, 874 F.3d 855 (5th Cir.) (consideration of prior offenses in imposing SR conditions)
Sealed Appellee v. Sealed Appellant, 937 F.3d 392 (5th Cir.) (permitting sex‑offender conditions based on remote prior sexual misconduct where connected)
United States v. Fields, 777 F.3d 799 (5th Cir.) (upholding sex‑offender‑related SR conditions tied to defendant’s history)
United States v. Longstreet, 603 F.3d 272 (5th Cir.) (sentencing court may not entertain certain collateral challenges at sentencing)
United States v. Miller, 665 F.3d 114 (5th Cir.) (analysis on what the district court may rely upon when imposing SR conditions)