United States v. Mayra Alaniz, 671 F. App'x 292

Mayra Alejandra Alaniz pleaded guilty to possession with intent to distribute heroin and submitted medical records showing bipolar disorder, depression, anxiety, and substance-abuse history.
Probation officer calculated a guidelines range (151–188 months) but the Government moved under U.S.S.G. § 5K1.1 for a reduced sentence; the district court sentenced Alaniz to 112 months.
The court imposed five years of supervised release and orally stated Alaniz was “requested to participate in a mental health program as deemed necessary and approved by the probation officer,” with costs based on ability to pay as determined by probation; the written judgment said she was “required” to participate.
Alaniz did not object at sentencing and timely appealed the mental-health-program special condition.
The Fifth Circuit reviewed for plain error and concluded the oral condition created an impermissible delegation of judicial authority to the probation officer regarding whether treatment was needed.
The Fifth Circuit vacated the mental-health special condition and remanded for resentencing with instruction that courts may require mandatory therapy but may not leave the decision whether therapy is required to the probation officer (only administrative details may be delegated).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mental-health special condition impermissibly delegated judicial authority to the probation officer	Alaniz: the condition left to the probation officer the decision whether she must participate in mental-health treatment, which is an improper delegation	Government/District Court: the condition was a permissible delegation limited to implementing details (and defendant did not object)	Vacated: the court found plain error — a court may delegate only details, not the decision whether therapy is required; ambiguous oral pronouncement impermissibly delegated authority

United States v. Torres–Aguilar, 352 F.3d 934 (5th Cir. 2003) (oral sentence controls when written judgment conflicts)
United States v. Rodriguez, 558 F.3d 408 (5th Cir. 2009) (standard of review for supervised-release conditions)
Puckett v. United States, 556 U.S. 129 (2009) (plain-error standard)
United States v. Franklin, 838 F.3d 564 (5th Cir. 2016) (sentencing is a core judicial function; limits on delegating therapy decisions to probation)
United States v. Johnson, 48 F.3d 806 (4th Cir. 1995) (limits on probation officer authority)
United States v. Gordon, 838 F.3d 597 (5th Cir. 2016) (erroneous mental-health condition can affect substantial rights)
Olano v. United States, 507 U.S. 725 (1993) (standards for correcting plain forfeited error)