United States v. Fonville, 20-7033

Fonville was convicted of being a felon in possession of a firearm and sentenced to 120 months' imprisonment.
As a special condition of supervised release, the district court required participation in mental-health treatment and compliance with treatment directives, “including the taking of prescription medications as directed by a mental health professional.”
The PSR reported a history of mental-health treatment and prior medication while incarcerated, but that Fonville was not currently prescribed psychotropic medication and could not identify diagnoses or prior prescriptions.
The district court adopted the PSR and imposed the medication requirement without on-the-record, particularized findings or any explanation justifying compulsory future medication.
Fonville did not object at sentencing and appealed, arguing plain error as to the medication mandate; the government urged the claim was not ripe and that the PSR supported the condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness of appeal	Challenge to procedural imposition is fit for review now; condition is reviewable despite future contingency	Condition is contingent on a mental-health professional prescribing medication, so not ripe	Court: appeal is prudentially ripe; fitness and hardship factors favor review
Validity of mandated future medication (plain-error review)	Medication mandate invades liberty; PSR facts insufficient; plain error review applies due to no objection	PSR provides adequate basis; similar conditions have been upheld	Court: plain error established; medication requirement vacated and remanded for resentencing with particularized findings and consideration of compelling circumstances

United States v. Malone, 937 F.3d 1325 (10th Cir. 2019) (requiring particularized findings and compelling circumstances before imposing a broad medication condition)
United States v. Burns, 775 F.3d 1221 (10th Cir. 2014) (special conditions that implicate fundamental rights require heightened justification)
United States v. Mike, 632 F.3d 686 (10th Cir. 2011) (recognizing significant liberty interest in avoiding involuntary psychotropic drugs)
United States v. Koch, 978 F.3d 719 (10th Cir. 2020) (district courts must make on-the-record, rigorous analyses when conditions implicate fundamental rights)
United States v. Cabral, 926 F.3d 687 (10th Cir. 2019) (discussing prudential ripeness doctrine and its factors)
Tex. Brine Co. v. Occidental Chem. Corp., 879 F.3d 1224 (10th Cir. 2018) (explaining the purpose of prudential ripeness)
United States v. Bennett, 823 F.3d 1316 (10th Cir. 2016) (setting out the two-factor ripeness inquiry)
United States v. Ford, 882 F.3d 1279 (10th Cir. 2018) (holding conditions contingent on another actor are generally not ripe)
United States v. Martinez-Torres, 795 F.3d 1233 (10th Cir. 2015) (plain-error review framework)
United States v. Barela, 797 F.3d 1186 (10th Cir. 2015) (vacatur of supervised-release conditions is appropriate where the record reveals no basis)