United States v. Charles Goodwin
2013 U.S. App. LEXIS 9295
| 7th Cir. | 2013Background
- Goodwin pleaded guilty to knowingly failing to register and update a registration as a sex offender under SORNA.
- He was sentenced to 27 months’ imprisonment followed by a life term of supervised release with ten conditions.
- Goodwin challenges SORNA’s delegation as unconstitutional, the district court’s miscalculation of the supervised-release Guidelines, and four challenged conditions.
- Historical facts: 1994 conviction for attempted lewd act in presence of a child; prior Florida and Illinois registrations and failures to re-register across interstate moves.
- PSR initially set offense level 10 and criminal history V, predicting a five-year to life supervised-release range; court imposed life term.
- On appeal, the court vacates the supervised-release portion and remands for resentencing, including reassessment of the conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of SORNA delegation | Goodwin contends § 16913(d) constitutes unconstitutional delegation. | Goodwin argues the Attorney General lacks clear standards for applying pre-enactment offenders to SORNA. | Nondelegation claim rejected; SORNA provides intelligible principle and defined agency and boundaries. |
| Plain-error in advisory Guidelines range for supervised release | PSR wrongly cites § 5D1.2(b)(2) to justify life term; miscalculation affected sentence. | District court relied on erroneous range and misapplied guidelines. | Plain-error established; five-year advisory range applies, with statutory minimum controlling; remand for resentencing. |
| Condition 4 (computer/Internet monitoring) | Monitoring and searches are reasonably related to the offense and protect the public. | No justification in record linking broad computer searches to the offense. | Condition 4 vacated; need for justification on remand. |
| Condition 5 (no minor contact without approved adult) and Conditions 6-7 | No-contact and content-restriction conditions may be appropriate in some cases. | District court failed to explain why these overly broad and vague restrictions are necessary. | Conditions 5, 6, and 7 vacated; require reasons on remand. |
Key Cases Cited
- Whitman v. American Trucking Ass’ns, 531 U.S. 457 (2001) (intelligible principles in delegation analysis)
- American Power & Light Co. v. SEC, 329 U.S. 90 (1946) (delegation boundaries framework)
- United States v. Dixon, 551 F.3d 578 (7th Cir. 2008) (nondelegation precedent on SORNA)
- Carr v. United States, 130 S. Ct. 2229 (2010) (Supreme Court—addressed Dixon; relevance to SORNA delegation)
- Jaimes-Jaimes, 406 F.3d 845 (7th Cir. 2005) (forfeiture versus waiver in rule-51 context)
- United States v. Anderson, 604 F.3d 997 (7th Cir. 2010) (plain-error review standard in sentencing)
- United States v. Gall, 552 U.S. 38 (2007) (sentencing range as starting point; reasonableness review)
- Rita v. United States, 551 U.S. 338 (2007) (post-Booker reasonableness presumption)
- United States v. Holm, 326 F.3d 872 (7th Cir. 2003) (limits on special-conditions deprivation of liberty)
- Angle, 598 F.3d 352 (7th Cir. 2010) (special-conditions must relate to offense and goals)
- Perazza-Mercado, 553 F.3d 65 (1st Cir. 2009) (vagueness/overbreadth in special-condition analysis)