United States v. Miles
411 F. App'x 126
10th Cir.2010Background
- Dr. Miles married a 14-year-old Cambodian girl and transported her to the U.S. in 2001.
- He pled guilty to false statements on a visa affidavit under 18 U.S.C. § 1001(a)(3).
- A prior indictment for transporting the minor for illicit sexual conduct was dismissed due to marriage to S.K.
- Evidence at sentencing showed Dr. Miles expressed sexual-preference for very young girls and engaged in abusive conduct with underage partners.
- The district court sentenced Miles to five years’ imprisonment and three years of supervised release with sex-offender conditions, including registration and treatment.
- Miles appealed, challenging the sex-offender conditions as not reasonably related to the offense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are sex-offender conditions reasonably related to the offense? | Miles argues the offense is not a sex offense, thus conditions aren’t related. | Miles contends the conditions are not tied to the offense's nature or his history. | Yes; conditions are reasonably related and not an abuse of discretion. |
| Does the district court properly address potential state-registration barriers? | Miles claims registration may be impossible where state laws differ. | Court provided process for states denying registration; flexibility exists. | Court satisfied procedural safeguards to handle registration issues. |
Key Cases Cited
- United States v. Hahn, 551 F.3d 977 (10th Cir. 2008) (abuse-of-discretion standard for supervised-release conditions)
- United States v. Carter, 463 F.3d 526 (6th Cir. 2006) (special conditions may be appropriate beyond explicit sex-offense context)
- United States v. Jiminez, 275 F. App’x 433 (5th Cir. 2008) (sex-offender conditions may be imposed where evidence supports risk)
- United States v. Genovese, 311 F. App’x 465 (2d. Cir. 2009) (affirms registration under broader risk considerations)
- United States v. Prochner, 417 F.3d 54 (5th Cir. 2008) (affirming sex-offender evaluation/treatment where risk assessed)
- United States v. Ybarra, 289 F. App’x 726 (5th Cir. 2008) (§ 3583(d) does not prohibit registration absent prior sex offenses)
- United States v. Fabiano, 169 F.3d 1299 (10th Cir. 1999) (sex offender registration considerations where offense not explicitly sexual)