United States v. Maria Alvarez, 880 F.3d 236

Alvarez was arrested at a border checkpoint after passengers presented birth certificates and a hidden third person (found in the trunk at ~94°F) was discovered; she pleaded guilty to transporting an undocumented alien.
PSR reported no mental or emotional-health problems, noted alcohol use, and recommended education and drug-treatment conditions but did not recommend mental-health treatment.
At sentencing the district court imposed 18 months imprisonment and two years supervised release, including special conditions for drug/alcohol treatment, education, and participation in a mental-health program; Alvarez did not object at sentencing but appealed the mental-health condition.
The judgment required Alvarez to participate in mental-health treatment and to pay costs based on ability to pay.
On appeal, Alvarez invoked plain-error review, arguing the district court failed to make the statutorily required factual findings showing the mental-health condition was reasonably related to the §3553(a) factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mental-health special condition was validly imposed	Alvarez: the district court made no factual findings and the record (PSR) contains no evidence she needed mental-health treatment; thus imposition was error	Government: the court’s imposition can be inferred from Alvarez’s traumatic history in the PSR and counsel’s comments—that mental-health treatment would benefit Alvarez	Vacated and remanded: plain error found. The district court failed to state factual findings tying the condition to §3553(a); the record does not clearly support an inference.
Whether plain-error relief is appropriate	Alvarez: error was clear, affected substantial rights (cost/time/privacy/stigma), and warrants correction	Government: condition is modifiable on supervised release and thus relief should be denied	Court exercised discretion to correct error: all four plain-error prongs satisfied; remand required to reconsider the condition.

Puckett v. United States, 556 U.S. 129 (plain-error framework established)
United States v. Prieto, 801 F.3d 547 (5th Cir.) (application of plain-error prongs)
United States v. Caravayo, 809 F.3d 269 (5th Cir.) (vacating special condition where record lacks support)
United States v. Salazar, 743 F.3d 445 (5th Cir.) (district courts must set forth factual findings to justify special probation conditions)
United States v. Weatherton, 567 F.3d 149 (5th Cir.) (statutory limits and §3553(a) relation for supervised-release conditions)
United States v. Fernandez, 776 F.3d 344 (5th Cir.) (district court discretion to impose special conditions)
United States v. Gordon, 838 F.3d 597 (5th Cir.) (vacating mental-health condition where unsupported)
United States v. Mendoza-Velasquez, 847 F.3d 209 (5th Cir.) (consideration of modifiability of condition in fourth plain-error prong)