United States v. Christopher Oliphant, 456 F. App'x 456

Oliphant pled guilty to making a bomb threat and threats against the President.
He challenges sex-offender related special conditions of supervised release.
District court imposed the special conditions without noting a notice requirement.
Discrepancy exists between the oral pronouncement and the written judgment about no-contact with minors.
Court analyzes vagueness of contact-with-minors restriction and association limitations.
Court affirms the district court’s imposition of conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Notice requirement for special conditions	Oliphant lacked notice before conditions	No plain error for lack of notice	No plain error; unclear post-Booker notice rule
Written vs oral judgment on no-contact	Discrepancy favors defendant	Ambiguity resolvable by record	Ambiguity resolved; remand unnecessary
Vagueness of location restriction	Restriction too vague	Language clarifies scope	Not overly vague; valid with modification interpretation
Association restrictions and liberty deprivation	Restriction overly broad	Rationally related to public protection	Not overly broad; sufficiently protective
Treatment condition and psycho-physiological testing	Unnecessary liberty deprivation	Ripe issue for review later	Not ripe for review

United States v. Weatherton, 567 F.3d 149 (5th Cir. 2009) (post-Booker notice requirement unclear)
United States v. Mireles, 471 F.3d 551 (5th Cir. 2006) (ambiguity between written and oral judgments)
United States v. Paul, 274 F.3d 166 (5th Cir. 2001) (fair notice for restrictions on contact with groups)
United States v. Rodriguez, 558 F.3d 408 (5th Cir. 2009) (public policy on protecting minors through conditions)
United States v. Booker, 543 U.S. 220 (U.S. 2005) (concerning guidelines and notice after Booker)
United States v. Carmichael, 343 F.3d 756 (5th Cir. 2003) (ripe-review framework for certain conditions)