United States v. Maurice Wilkins, 909 F.3d 915

Maurice Wilkins has a lengthy criminal history including violent offenses and drug convictions; prior sentences included lengthy imprisonment and supervised release terms.
During an earlier supervised-release term Wilkins committed multiple violations, including assaulting family members; the district court previously revoked release and imposed prison time and supervised release, which this Court affirmed.
On his second term of supervised release (begun Nov. 2016), Wilkins admitted three violations: failure to provide a urine sample, providing a diluted sample, and assaulting his wife.
The parties agreed the Sentencing Guidelines range for revocation was 6–12 months; the district court imposed 12 months’ imprisonment followed by three years’ supervised release.
As a special condition of supervised release, the court prohibited Wilkins from contacting his wife directly or indirectly for the entire supervision term, but indicated the condition could be lifted if Wilkins stabilized and the probation office could facilitate supervised child exchanges.

Issue	Plaintiff's Argument	Defendant's Argument (Wilkins)	Held
Substantive reasonableness of 12-month revocation sentence	Government: sentence within Guidelines and justified by history and violations	Wilkins: court ignored his progress and mitigation, overemphasized past conduct	Affirmed — within Guidelines and court did not abuse discretion in weighing §3553(a) factors
Validity of no-contact special condition	Government: condition reasonably related to protection of victim given Wilkins’s violent history	Wilkins: condition is an excessive deprivation of liberty	Affirmed — individualized inquiry; condition reasonably related to §3553(a) goals and not greater than necessary

United States v. Merrival, 521 F.3d 889 (8th Cir. 2008) (revocation sentences reviewed for reasonableness under abuse-of-discretion standard)
United States v. Kreitinger, 576 F.3d 500 (8th Cir. 2009) (abuse of discretion defined for sentencing weight of factors)
United States v. Farmer, 647 F.3d 1175 (8th Cir. 2011) (district courts have wide latitude in weighing §3553(a) factors)
United States v. Petreikis, 551 F.3d 822 (8th Cir. 2009) (Guidelines-range sentences are presumptively reasonable)
United States v. Hobbs, 710 F.3d 850 (8th Cir. 2013) (special conditions of supervised release reviewed for abuse of discretion)
United States v. Cooper, 171 F.3d 582 (8th Cir. 1999) (special conditions must be reasonably related to statutory sentencing factors and not more restrictive than necessary)
United States v. Deatherage, 682 F.3d 755 (8th Cir. 2012) (court must make individualized findings on record to support special conditions)