United States v. John McCarthy, 24-1989

John J. McCarthy was convicted of attempted enticement of a minor for prostitution under 18 U.S.C. § 2422(b) and initially sentenced to 120 months in prison and five years of supervised release.
After release, McCarthy violated the conditions of his supervised release.
Due to these violations, his supervised release was revoked and he was resentenced to six months in prison and a lifetime term of supervised release.
Violations included possession of an unapproved electronic device and searching or storing content related to child exploitation.
McCarthy appealed only the imposition of the lifetime supervised release term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substantive reasonableness of lifetime supervised release	Lifetime supervision is unreasonable for first-time, promptly admitted/corrected violations	Court properly weighed § 3553(a) factors; original offense and public danger are paramount	Lifetime supervision reasonable; district court did not err

United States v. Rollins, 105 F.4th 1115 (8th Cir. 2024) (articulates review standard for substantive reasonableness of a sentence)
United States v. Phillips, 785 F.3d 282 (8th Cir. 2015) (upholds lifetime supervised release if defendant poses continuing danger to the community)