United States v. Marvin Gaynor, 530 F. App'x 536

Gaynor pleaded guilty to being a felon in possession of a firearm in the Western District of Tennessee.
Sentence: 30 months’ imprisonment followed by three years of supervised release, with five special conditions imposed, including two non-mandatory ones at issue.
During sentencing the district court announced a financial-disclosure condition and an income-tax-return filing requirement among the special conditions.
The written judgment memorialized the two conditions as: make full financial disclosure to the Probation Officer and file income tax returns while on supervision.
Gaynor did not object at sentencing; he appealed after the judgment challenged only the two conditions.
The court held the appeal ripe and reviewed the challenged conditions for abuse of discretion under the proper standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness for review of supervised-release conditions	Gaynor argues the conditions are not ripe until after confinement ends.	Gaynor contends conditions are mandatory and thus reviewable now.	Conditions ripe for review; not merely conjectural.
Standard of review for unobjected conditions	Gaynor asserts abuse-of-discretion review; seeks substantive review.	District court’s imposition should be reviewed for plain error or abuse-of-discretion.	Court applies abuse-of-discretion standard (and in any event plain-error review would uphold).
Reasonableness of financial-disclosure & tax-return conditions under 18 U.S.C. § 3583(d)	Disclosures and tax returns are not reasonably related to offense or characteristics.	Conditions are reasonably related to Gaynor’s history, rehabilitation, and deterrence.	Conditions upheld as reasonably related, not overly burdensome, and tailored to rehabilitation.
Discrepancy between oral pronouncement and written judgment	Written judgment omits language about disclosures stated orally.	No discrepancy; written terms clarify oral intent.	No discrepancy; written judgment aligns with oral pronouncement.

United States v. Carter, 463 F.3d 526 (6th Cir. 2006) (standard abuse of discretion for supervised-release conditions)
United States v. May, 568 F.3d 597 (6th Cir. 2009) (abuse of discretion review of conditions; § 3553 factors)
United States v. Brogdon, 503 F.3d 555 (6th Cir. 2007) (abuse-of-discretion review in supervised release context)
United States v. Zobel, 696 F.3d 558 (6th Cir. 2012) (ripeness and review of discretionary conditions)
United States v. Inman, 666 F.3d 1001 (6th Cir. 2012) (financial-disclosure conditions relate to history/characteristics)
United States v. Cofield, 233 F.3d 405 (6th Cir. 2000) (oral pronouncement controls over written judgment when conflicting)