United States v. James Taylor, 997 F.3d 1348

In Feb 2019 officers found James Taylor unresponsive in a truck; during arrest they recovered a 9mm handgun and a knife and learned Taylor was a convicted felon. He was indicted under 18 U.S.C. § 922(g)(1) and pled guilty.
Presentence calculation: offense level 12, criminal-history category IV, guideline range 21–27 months.
Government sought 42 months based on repeated illegal firearm possession; Taylor sought a within-guidelines term plus substance-abuse treatment and stressed recent sobriety and education efforts.
District Court imposed 30 months’ imprisonment (three months above the guideline range) and 3 years’ supervised release, including a condition authorizing electronic-device searches upon reasonable suspicion and where the specific area is likely to contain evidence.
Taylor appealed, challenging (1) the electronic search condition as overbroad/unrelated to sentencing goals and (2) the substantive reasonableness of the upward variance to 30 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of electronic-device search condition on supervised release	Taylor: condition is overbroad, vague, and unrelated to deterrence/rehabilitation	Gov/District Ct: condition reasonably relates to Taylor’s recidivist history, drug use, and risk of obtaining guns online; searches limited by reasonable suspicion and scope	Affirmed — condition permissible and not vague/overbroad; district court did not abuse discretion
Substantive reasonableness of 30‑month upward variance	Taylor: above-guidelines variance unjustified; within-guidelines plus treatment would suffice given prior probation and recent sobriety	Gov/District Ct: substantial recidivism for illegal gun possession warrants stronger deterrent; 30 months sufficient and below statutory max	Affirmed — district court reasonably weighed §3553(a) factors and did not abuse discretion

Moran, 573 F.3d 1132 (11th Cir. 2009) (abuse-of-discretion review and factors for special supervised-release conditions)
Gall, 552 U.S. 38 (2007) (reasonableness standard for appellate review of sentences)
Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015) (burden on challenger and deference to sentencing court)
Nash, 438 F.3d 1302 (11th Cir. 2006) (conditions related to §3553(a) are not vague/overbroad)
Zinn, 321 F.3d 1084 (11th Cir. 2003) (special condition need not be supported by every §3553(a) factor)
Bull, 214 F.3d 1275 (11th Cir. 2000) (conditions need not relate to the specific instant offense)
Castillo, 816 F.3d 1300 (11th Cir. 2016) (privacy intrusions may be justified to reduce recidivism)
Irey, 612 F.3d 1160 (11th Cir. 2010) (degree of variance requires commensurate justification)
Gonzalez, 550 F.3d 1319 (11th Cir. 2008) (acknowledgment that court considered §3553(a) factors is sufficient)