United States v. Eugene Rantanen, 684 F. App'x 517

Eugene Rantanen was convicted of sexual abuse of a minor (federal prosecution in Indian country), served prison time, and began a ten-year term of supervised release.
Throughout supervision he repeatedly violated conditions (alcohol and drug use, failure to attend treatment, contacting protected persons, leaving residence without authorization, resisting officers), accruing multiple revocations and additional custody terms.
At a 2016 revocation hearing Rantanen admitted most violations and asked the court to order him removed from Baraga County, which he said triggered his relapse and criminal conduct.
The district court revoked supervised release, imposed a 14-month custodial sentence, an eight-year-ten-month term of supervised release, and added a special condition barring Rantanen from Baraga County “for all purposes.”
Rantanen did not object in district court but appealed the geographic exclusion, arguing it was an overly broad deprivation of liberty and lacked necessary exceptions for family, tribal, religious, or emergency visits.
The Sixth Circuit reviewed for plain error and affirmed, finding the ban reasonably related to rehabilitation and public protection and not plainly erroneous given Rantanen’s history and agreement with the court that Baraga County harmed his recovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court adequately stated rationale for special condition	Rantanen: court failed to justify an absolute ban from county	Government: court explained it sought to remove harmful environment the defendant identified	Held: Court adequately stated rationale in open court; no obvious error
Whether exclusion is reasonably related to §3553 goals (rehabilitation and public protection)	Rantanen: total ban is not reasonably related; less restrictive alternatives exist	Government: exclusion targets a documented causal factor for repeated violations	Held: Condition reasonably related to rehabilitation and public safety
Whether the exclusion imposes greater deprivation of liberty than necessary	Rantanen: absolute, long-term ban (no probation-officer permission) unduly restrictive, limits tribal/family/religious rights	Government: prior, narrower measures failed; limited to one county, not wider area	Held: Not plainly greater than necessary under plain-error review; district court could modify later if warranted
Whether duration without exceptions (nearly nine years) is excessive	Rantanen: length and lack of exceptions make it unreasonable	Government: lengthy supervision justified by repetitive violations and risk; modification remains available under §3583(e)	Held: Court uneasy but affirmed; no plain error given facts and availability of later modification

United States v. Zobel, 696 F.3d 558 (6th Cir. 2012) (plain-error standard when defendant fails to object at sentencing)
United States v. Brogdon, 503 F.3d 555 (6th Cir. 2007) (requirement that district court state rationale for special conditions on the record)
United States v. Carter, 463 F.3d 526 (6th Cir. 2006) (same; quoted standard for articulating reasons)
United States v. Ritter, 118 F.3d 502 (6th Cir. 1997) (supervised-release conditions must be reasonably related to rehabilitation and public protection)
United States v. Alexander, 509 F.3d 253 (6th Cir. 2007) (caution against imposing broad geographic restrictions that remove defendants far from family/community)
United States v. Watson, 582 F.3d 974 (9th Cir. 2009) (upholding geographic restrictions with probation-officer permission exceptions)
United States v. Sicher, 239 F.3d 289 (3d Cir. 2000) (addressing scope and limits of geographic conditions)
United States v. Garrasteguy, 559 F.3d 34 (1st Cir. 2009) (upholding multi-year county exclusion without probation-officer exception under plain-error review)
United States v. Lowenstein, 108 F.3d 80 (6th Cir. 1997) (district court may modify supervised-release conditions later under §3583(e))
United States v. Inman, 666 F.3d 1001 (6th Cir. 2012) (plain-error standard articulated for appellate relief)