United States v. Germaine Bryant, 2014 U.S. App. LEXIS 10954

Defendant pleaded guilty to a federal drug offense and received a below-guidelines sentence of 144 months (guidelines 188–235 months). Lawyer filed an Anders brief; defendant did not respond or seek to withdraw plea.
Anders brief identified no nonfrivolous grounds to challenge the 144‑month term; it noted a possible ineffective‑assistance claim but explained that such claims are usually inappropriate on direct appeal.
The written judgment listed supervised‑release conditions (3‑year term) but the presentence report and defense counsel were not shown the probation officer’s sentencing recommendations (per S.D. Ill. local practice and Fed. R. Crim. P. 32(e)(3)).
The district judge imposed 15 standard conditions (13 listed) and 7 special conditions (8 listed in writing, with discrepancies between oral and written statements); reasons were given for only 4 special conditions and none for the standard conditions.
Several imposed conditions were problematic: one financial condition took effect pre‑release (contradicted by Bureau of Prisons program and Seventh Circuit precedent), some financial conditions were disproportionate to the tiny $100 fine, and one mandatory statutory notification condition appeared inapplicable to this fine amount.
Court noted lack of notice to defense of special conditions (Scott), errors in written sentence (gender references, extra conditions), and that oral statement controls over written judgment when discrepant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ineffective‑assistance claim may be raised on direct appeal	Anders brief suggested defendant may wish to raise it	Such claims are better raised in collateral proceedings where evidence can be developed	Ineffective‑assistance claims are generally inappropriate on direct appeal (citing Massaro)
Whether defendant had adequate notice of special conditions of supervised release	N/A (court reviews notice issue sua sponte)	Defense lacked notice of probation officer recommendations and unexpected special conditions	Notice is required for out‑of‑ordinary special conditions; lack of notice is problematic (Scott) but no reversal due to Anders posture
Whether judge provided adequate reasons for discretionary conditions	N/A	Judge failed to explain how standard and many special conditions related to §3553(a) factors	Court criticized absence of reasons; judges must state reasons for discretionary supervised‑release conditions (Siegel authority noted)
Validity and timing of pre‑release financial deductions and notification condition	Judge imposed pre‑release payment schedule and notification condition tied to fines	Pre‑release deductions conflict with BOP I.F.R.P. and Sawyer; notification statutory provision may not apply to $100 fine	Court questioned authority to impose some pre‑release financial conditions and inapplicability of statutory notification; but did not vacate sentence given Anders brief and defendant’s silence

Massaro v. United States, 538 U.S. 500 (2003) (ineffective‑assistance claims generally raised in collateral proceedings)
Irizarry v. United States, 553 U.S. 708 (2008) (no notice required for ordinary variances under §3553(a))
Scott v. United States, 316 F.3d 733 (7th Cir. 2003) (notice required before imposing out‑of‑the‑ordinary special supervised‑release conditions)
United States v. Sawyer, 521 F.3d 792 (7th Cir. 2008) (limitations on judicial orders directing prisoners’ wages pre‑release)
United States v. Peterson, 711 F.3d 770 (7th Cir. 2013) (discussing secrecy of probation officer’s sentencing recommendations)
United States v. Cephus, 684 F.3d 703 (7th Cir. 2012) (oral sentence controls over written judgment when they differ)
United States v. McHugh, 528 F.3d 538 (7th Cir. 2008) (same rule on oral vs. written sentencing inconsistencies)