United States v. Ford, 882 F.3d 1279

Steven Ford had a 1998 Kansas conviction for Indecent Liberties with a Child (victim age 13) and was incarcerated thereafter for most of the intervening years.
Ford later was convicted in federal court (firearms offenses) and after a §2255 proceeding was re-sentenced to 240 months’ imprisonment plus three years’ supervised release.
At sentencing the district court imposed two sex-offender-related special conditions: (1) a mandatory sex-offense-specific risk assessment upon release; (2) treatment if recommended by the assessment, which could include probation- or provider-directed clinical polygraph exams.
Ford objected, arguing the 1998 sex conviction was too temporally remote and unrelated to his federal offenses to justify sex-offender conditions.
While this appeal was pending Ford pleaded guilty in an unrelated Oklahoma murder case and was sentenced to life without parole; the government argued this made review prudentially unripe.
The Tenth Circuit considered ripeness and reasonableness: it held the assessment condition was ripe and reasonable, but the polygraph condition was not ripe because it is contingent on the assessment and the probation officer/treatment provider.

Issue	Ford's Argument	Government's Argument	Held
Prudential ripeness for review of supervised-release conditions	Appeal is appropriate now; he faces hardship if review is withheld	Case may be unripe because long federal term and new life sentence may prevent supervised release	Ripeness appropriate for assessment condition but not for polygraph condition (polygraph is contingent)
Lawfulness of requiring sex-offender risk assessment as a special condition	Prior sex conviction (19 years old, when he was 17) is too temporally remote and unrelated to federal offenses	Condition is justified by prior conviction involving a minor, lack of prior sex-offender treatment, and long incarceration limiting probative value of a clean record	District court did not abuse discretion; assessment condition is reasonable under §3583(d)

United States v. Bennett, 823 F.3d 1316 (10th Cir. 2016) (prudential ripeness framework for supervised-release condition challenges)
United States v. White, 244 F.3d 1199 (10th Cir. 2001) (direct appeals of supervised-release conditions usually ripe)
United States v. Wayne, 591 F.3d 1326 (10th Cir. 2010) (need to raise supervised-release condition on direct appeal or risk forfeiture)
United States v. Dougan, 684 F.3d 1030 (10th Cir. 2012) (seventeen-year-old sex-offense conviction found too remote to support sex-offender conditions absent stronger nexus)
United States v. Bear, 769 F.3d 1221 (10th Cir. 2014) (district courts have broad discretion; sex-offender conditions may be imposed when related to defendant’s history)
United States v. Hahn, 551 F.3d 977 (10th Cir. 2008) (district court must state reasons on the record for special supervised-release conditions)
United States v. Vaquera-Juanes, 638 F.3d 734 (10th Cir. 2011) (withholding review where it is certain the defendant will never be subject to supervised release)