United States v. Charles D. St. Clair
926 F.3d 386
| 7th Cir. | 2019Background
- In Sept. 2016 St. Clair pleaded guilty to being a felon in possession of a firearm and was sentenced to 33 months imprisonment plus 1 year supervised release; the court proposed 6 mandatory and 14 discretionary conditions.
- St. Clair began supervised release in Aug. 2017 and soon violated multiple conditions (marijuana use, missed tests, failure to report).
- A probation office “summary report of violations” recommended revocation, a prison term, continued supervised release, and reimposition of 17 prior conditions.
- At the April 2018 revocation hearing St. Clair admitted the violations, waived formal reading of conditions, acknowledged prior notice and counsel review, and told the judge he had no objections.
- The district court revoked release, sentenced St. Clair to one year imprisonment plus one year supervised release, and imposed the 17 discretionary conditions (including a condition forbidding presence at places where controlled substances are illegally used/sold).
- On appeal St. Clair argued the court failed to justify the discretionary conditions and that one condition was vague and relied on a superseded Guidelines provision; the Seventh Circuit found he waived these objections and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether St. Clair preserved challenge to supervised-release conditions | St. Clair: did not waive; district court failed to justify discretionary conditions and used an outdated Guidelines citation | Government: St. Clair received advance notice, reviewed conditions with counsel, and expressly waived objections at revocation hearing | Waived — St. Clair expressly acknowledged notice, discussed conditions with counsel, and said he had no objections, so appellate review is barred |
| Whether a condition forbidding presence at places of illegal drug activity is unconstitutionally vague or based on inaccurate Guidelines | St. Clair: the term “place” is vague; court relied on superseded U.S.S.G. §5D1.3(c) language | Government: objections forfeited by waiver; merits not reached | Forfeited/Waived — court declined to reach merits because St. Clair waived the challenge |
| Whether a summary report suffices as notice equivalent to a presentence report | St. Clair: no presentence report → insufficient notice of conditions | Government: the summary report functioned as an equivalent notice and was acknowledged at hearing | Summary report is a functional equivalent of a presentence report for notice purposes; notice was adequate |
| Whether lack of written justifications for discretionary conditions is non-waivable | St. Clair: justifications were absent and cannot be waived | Government: absence of justification is a merits argument, waivable at sentencing/revocation | Waived — challenges to sufficiency of justifications are merits issues; defendant may raise them at sentencing or via 18 U.S.C. §3583(e)(2), but not after expressly waiving at revocation |
Key Cases Cited
- United States v. Gabriel, 831 F.3d 811 (7th Cir.) (defendant waived objections to supervised-release conditions after receiving notice and saying he had no objections)
- United States v. Bloch, 825 F.3d 862 (7th Cir.) (same; waiver applies where defendant had notice and did not object)
- United States v. Lewis, 823 F.3d 1075 (7th Cir.) (waiver of challenge to lack of justification for supervised-release conditions)
- United States v. Salinas, 365 F.3d 582 (7th Cir.) (summary report can serve as equivalent to presentence report for notice/factual-error purposes)
- United States v. Williams, 840 F.3d 865 (7th Cir.) (explaining §3583(e)(2) as the proper avenue to seek modification of supervised-release conditions)
- United States v. Preacely, 702 F.3d 373 (7th Cir.) (arguing that challenges to vague conditions belong at sentencing or under §3583(e)(2), not in revocation proceedings)