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United States v. Darrell W. Jones
2015 U.S. App. LEXIS 14571
7th Cir.
2015
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Background

  • Jones committed repeated sexual offenses against a prepubescent girl in the 1980s and was convicted in Florida; he later failed to register as a sex offender in 2010s, leading to federal charges under SORNA § 2250(a).
  • He entered a naked guilty plea and was sentenced to 18 months’ imprisonment and 5 years of supervised release, with standard conditions plus several special conditions proposed by probation.
  • At the first sentencing, the court adopted the PSR and denied defense requests to strike or modify several conditions; it concluded the guidelines range was reasonable and imposed sentence at the bottom of the range.
  • After Siegel v. United States was decided, a supplemental PSR and a second hearing were held to address proposed supervised-release conditions; the court adopted seven conditions tailored to monitoring and control, with some modifications.
  • Jones challenged the adequacy of treatment-related and contact/minor-contact conditions as tailored to his offense and characteristics; the district court considered the 3553(a) factors but provided limited explicit rationale for rejection of mitigation arguments.
  • The Seventh Circuit affirmed, holding the district court meaningfully considered mitigation arguments and that the supervised-release conditions were reasonably related to the offense, did not unduly deprive liberty, and complied with 18 U.S.C. § 3583(d).

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Adequacy of mitigation consideration Jones argues the court gave inadequate consideration to mitigation arguments. Jones contends the court did not meaningfully explain or tailor reasoning for rejecting mitigation. The court meaningfully considered mitigation arguments; failure to spell out every rationale explicitly did not constitute error.
Tailoring of supervised-release conditions Jones asserts conditions are not appropriately tailored to his history and characteristics. Jones's history and risks justify the conditions, and probation's assessment supported tailoring. Conditions are reasonably related to offense and characteristics, not overbroad, and satisfy 18 U.S.C. § 3583(d).
Compliance with procedural requirements for non-mandatory conditions Jones argues procedural requirements and 3553(a) factors were not properly applied to justify conditions. The court followed best practices, consulted a supplemental PSR, and held a second hearing, with consideration of 3553(a) factors. Procedural requirements were satisfied; the court properly justified the conditions within the 3553(a) framework.

Key Cases Cited

  • United States v. Diekemper, 604 F.3d 345 (7th Cir. 2010) (imposition and justification of supervised-release conditions require meaningful consideration)
  • United States v. Kappes, 782 F.3d 828 (7th Cir. 2015) (advocates advance notice of proposed conditions and thorough appellate scrutiny)
  • United States v. Siegel, 753 F.3d 705 (7th Cir. 2014) (supervised-release needs justification with reference to § 3553(a) factors)
  • United States v. Baker, 755 F.3d 515 (7th Cir. 2014) (consideration of defendant's history and recent factors in tailoring conditions)
  • United States v. Evans, 727 F.3d 730 (7th Cir. 2013) (long-ago offenses can still justify conditions based on history and characteristics)
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Case Details

Case Name: United States v. Darrell W. Jones
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Aug 19, 2015
Citation: 2015 U.S. App. LEXIS 14571
Docket Number: 14-2787
Court Abbreviation: 7th Cir.