United States v. Domingo Blount, 777 F.3d 368

Background

The court consolidated four appeals challenging conditions of supervised release imposed at sentencing; defendants did not appeal their prison terms (except Blount who also challenged enhancement).
Supervised release (18 U.S.C. § 3583) is imposed at sentencing and takes effect after imprisonment; it augments, rather than shortens, punishment and may lead to reimprisonment for violations.
The opinion identifies systemic problems: long check‑the‑box condition lists, vague/overbroad conditions, judges’ failure to state § 3553(a) reasoning for conditions, late notice to defendants, and underresourced probation offices.
The court emphasized that conditions are part of the sentence and thus the judge must apply the § 3553(a) factors and state reasons on the record at sentencing; vague or unjustified conditions are reversible.
In each of the four cases (Thompson, Ortiz, Bates, Blount) the district courts imposed numerous nonmandatory or ambiguous conditions without adequate explanation; the judgments were vacated and remanded for resentencing to reconsider and explain supervised‑release conditions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether conditions of supervised release require consideration of § 3553(a) and on‑the‑record reasons	Plaintiffs (appealing defendants) argued some conditions were vague, overbroad, or unsupported by § 3553(a) analysis	Government argued conditions were proper and that probation officers can clarify vague terms post‑sentence	Court: Conditions are part of the sentence; judges must apply § 3553(a) and state reasons on the record; vague/unjustified conditions vacated and remanded
Whether lifetime or long future terms are permissible without explanation	Plaintiffs argued indefinite/long terms imposed without justification (e.g., lifetime supervised release) are improper	Government asserted courts have discretion and terms can later be modified	Court: Long or lifetime terms can be imposed but require on‑the‑record justification; misunderstanding about modification (judge’s error) noted and corrected
Whether the oral sentence or written judgment controls when they conflict	Plaintiffs relied on oral pronouncement when condition omitted from oral sentence	Government relied on written judgment	Court: Oral sentencing controls; conditions appearing only in written judgment but absent from oral statement may not be binding
Whether broadly worded standard conditions (e.g., "answer truthfully," "allow visits and plain‑view searches") violate rights or are too vague	Plaintiffs argued these conditions abridge constitutional rights or are unconstitutionally broad	Government argued supervisory need and probation officer discretion cure ambiguities	Court: Such conditions may implicate constitutional concerns and are too broad without individualized § 3553(a) justification; remand required
Whether judges may rely on probation officers or parties’ agreement to justify conditions	Plaintiffs argued judge must independently apply § 3553(a) rather than defer to parties or probation	Government argued reliance on probation recommendations and negotiated agreements is acceptable	Court: Judge cannot abdicate sentencing judgment; agreements/recommendations do not relieve duty to apply § 3553(a) and explain reasons
Whether appellate courts should narrow ambiguous conditions or remand	Plaintiffs sought vacatur/remand for clarification	Government urged upholding and practical cure by probation officer interpretation	Court: Prefer district courts narrow/justify conditions; appellate narrowing is less desirable—remand for resentencing and explanation

Key Cases Cited

United States v. Siegel, 753 F.3d 705 (7th Cir. 2014) (criticizes vagueness and administration of supervised‑release conditions)
United States v. Booker, 543 U.S. 220 (2005) (requirement that sentencing courts consider statutory factors in imposing sentence)
Irizarry v. United States, 553 U.S. 708 (2008) (notice at sentencing and Rule 32 practice; courts should permit opportunity to address surprising sentencing facts)
United States v. Goodwin, 717 F.3d 511 (7th Cir. 2013) (conditions must be reasonably related to offense and defendant; district court must explain)
United States v. Murray, 692 F.3d 273 (3d Cir. 2012) (interpretation of primary purpose of supervised release and § 3553(a) scope)
United States v. McKissic, 428 F.3d 719 (7th Cir. 2005) (upholding certain supervised‑release employment/GED conditions on particular records)
United States v. Bryant, 754 F.3d 443 (7th Cir. 2014) (notice requirements for non‑statutory conditions)
United States v. Johnson, 765 F.3d 702 (7th Cir. 2014) (oral pronouncement controls over written judgment)
United States v. Tejeda, 476 F.3d 471 (7th Cir. 2007) (probation officer cannot exercise unfettered discretion to define sentence terms)