United States v. Eaglin
913 F.3d 88
| 2d Cir. | 2019Background
- Defendant Jarret Eaglin convicted in 2003–04 (state statutory sexual offenses involving teenagers); later convicted in federal court (2012) for failing to register as a sex offender and sentenced to prison plus supervised release.
- Eaglin repeatedly violated supervised-release conditions over many years (failures to register, treatment noncompliance, unapproved travel, possession/viewing of adult pornography, unregistered e-mail accounts).
- After a 2015 warrant and subsequent prison term, the Northern District of New York imposed an 11-year supervised-release term that included: (1) a near-total ban on accessing the Internet (except with court/Probation approval) and (2) a blanket ban on viewing/possessing legal adult pornography.
- District Court justified the conditions by citing risk factors: Eaglin’s prior sexual convictions, instances of using an Internet-capable device to seek partners, and prior undisclosed Internet use.
- Eaglin appealed, arguing both conditions were overbroad, not reasonably related to his federal conviction (failure to register), and imposed greater deprivation of liberty than necessary under 18 U.S.C. § 3583(d) and § 3553(a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a near-total Internet ban as a supervised-release condition was permissible | Gov't: ban needed to protect public and deter/reduce risk because Eaglin used Internet to find partners and view pornography | Eaglin: ban is overbroad, not tied to the failure-to-register conviction, unduly burdens First Amendment and reintegration needs | Court: ban is substantively unreasonable; Internet access implicates modern First Amendment interests and the record lacks adequate support or tailoring |
| Whether a blanket ban on legal adult pornography was permissible | Gov't: pornography ban necessary to prevent high-risk sexual behavior and protect public | Eaglin: possession of lawful adult pornography is protected and ban is not reasonably related to his offense or recidivism risk | Court: pornography ban is substantively unreasonable; record lacks findings linking adult-porn access to recidivism or sentencing goals |
| Scope of review and heightened scrutiny when conditions implicate constitutional rights | N/A (procedural posture) | N/A | Court: when constitutional rights implicated, reviewing court requires close scrutiny and individualized, recorded findings by district court |
| Whether less restrictive alternatives (monitoring) were adequate | Gov't: previous monitoring failed because Eaglin still met an adult through online means | Eaglin: monitoring is less restrictive and permits reintegration (employment, treatment) | Court: record did not explain why monitoring was insufficient; less restrictive, tailored measures are preferred |
Key Cases Cited
- Carpenter v. United States, 138 S. Ct. 2206 (2018) (recognizing modern digital devices as indispensable to participation in society)
- Packingham v. North Carolina, 137 S. Ct. 1730 (2017) (striking overly broad statutory ban on sex-offender access to social-media sites; First Amendment limits)
- Riley v. California, 134 S. Ct. 2473 (2014) (noting privacy and societal importance of cell phones and digital data)
- United States v. Peterson, 248 F.3d 79 (2d Cir. 2001) (vacating overly broad Internet ban as unrelated to conviction)
- United States v. Myers, 426 F.3d 117 (2d Cir. 2005) (standards for special conditions of supervised release under § 3583(d))
- United States v. Sofsky, 287 F.3d 122 (2d Cir. 2002) (rejecting total Internet ban where it unduly restricted lawful online activity)
- United States v. Browder, 866 F.3d 504 (2d Cir. 2017) (upholding narrowly tailored computer-monitoring condition for child-pornography offender)
- United States v. Simmons, 343 F.3d 72 (2d Cir. 2003) (discussing limits on regulating possession of pornographic materials for supervisees)