United States v. Morales-Cruz
712 F.3d 71
| 1st Cir. | 2013Background
- Morales-Cruz pled guilty to failure to register under SORNA in this case and received a 48-month sentence with 10 years of supervised release; a condition required participation in sex offender and/or mental health treatment programs arranged by the probation officer.
- Defendant has a 1994 sex offense conviction (criminal sexual assault) and prior failures to register in NJ, Florida, and Puerto Rico; he also has a long criminal history including battery and probation violations.
- The district court imposed non-standard supervised release conditions tailored to Morales-Cruz, including a sex-offender treatment requirement.
- Morales-Cruz argues the sex-offender treatment condition is not reasonably related to the offense or his history given the long time since the 1994 offense.
- The First Circuit reviews the district court’s supervised-release conditions for abuse of discretion and considers whether the condition is reasonably related to 3553(a) factors and to deterrence and public safety.
- The majority affirms the district court’s imposition of the sex-offender treatment condition, finding a reasonable relationship to Morales-Cruz’s history and offense, and to the goals of deterrence and community protection; the dissent objects, arguing the condition is not reasonably related and is an overbroad restriction given the time elapsed since the sex offense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the sex-offender treatment condition reasonably related to the offense and Morales-Cruz’s history? | Morales-Cruz | Morales-Cruz | Yes; condition reasonably related; affirmed |
Key Cases Cited
- United States v. York, 357 F.3d 14 (1st Cir. 2004) (outlines criteria for imposed supervised-release conditions and relation to 3553(a))
- McKune v. Lile, 536 U.S. 24 (U.S. 2002) (sex-offender treatment programs as rehabilitative tools in correctional contexts)
- Dougan v. United States, 684 F.3d 1030 (10th Cir. 2012) (remote sex-offense convictions may be insufficient to justify sex-offender conditions)
- Rogers v. United States, 468 F. App’x 359 (4th Cir. 2012) (vacatur of sex-offender condition when not tied to offense/history)
- Sharp v. United States, 469 F. App’x 523 (9th Cir. 2012) (sex-offender condition reversed when offense remote and unrelated)