United States v. Peter Robert Bobal, 981 F.3d 971

Peter Bobal, a registered sex offender, exchanged sexually explicit texts and sent an explicit photo to someone he believed was a 14‑year‑old; an FBI agent later posed as the minor and arranged a meeting where Bobal was arrested.
Indicted on two counts: attempt to persuade a minor to engage in sexual activity (18 U.S.C. § 2422(b)) and committing a felony involving a minor while required to register as a sex offender (18 U.S.C. § 2260A).
Bifurcated trial: Bobal stipulated that he was a registered sex offender (an element of Count 2); the jury convicted him on the § 2422(b) count earlier the same day.
During closing, the prosecutor misstated that Bobal had stipulated to Count 2 and argued the only verdict on Count 2 was guilty; Bobal did not object at trial but moved for a new trial afterward, which the district court denied.
Sentenced to 240 months’ imprisonment and lifetime supervised release with a special condition prohibiting computer use except for work and with prior court approval; Bobal appealed, raising plain‑error review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prosecutor's closing remarks required a new trial on Count 2 (§ 2260A)	Prosecutor misstated the law (said Bobal stipulated to Count 2 and that the only verdict for Count 2 must be guilty), likely prejudicing the jury	Remarks were isolated/slips or persuasive argument; jury was instructed statements are not evidence; conviction on Count 2422(b) plus stipulation established Count 2 elements	No plain error. Remarks were not improper or prejudicial; district court cured any problem with jury instructions; conviction affirmed
Whether a lifetime supervised‑release condition banning computer use (except for work with court approval) is unconstitutional post‑Packingham	Packingham renders blanket computer/internet restrictions invalid; Bobal’s restriction is an overbroad First Amendment violation	Packingham is distinguishable: restriction is limited to supervised release (not post‑sentence), tailored to offense involving electronic communications, and permits court approval/modification; Eleventh Circuit precedent permits such conditions	No plain error. Condition upheld as constitutionally permissible and supported by circuit precedent; sentence affirmed

Packingham v. North Carolina, 137 S. Ct. 1730 (2017) (Struck down broad law barring registered sex offenders from accessing social‑networking sites on First Amendment grounds)
United States v. Zinn, 321 F.3d 1084 (11th Cir. 2003) (upheld limited internet restriction as reasonable supervised‑release condition)
United States v. Carpenter, 803 F.3d 1224 (11th Cir. 2015) (upheld lifetime computer restriction on plain‑error review)
United States v. Knights, 534 U.S. 112 (2001) (permits reasonable conditions on probation/supervised release that limit some liberties)
United States v. Holena, 906 F.3d 288 (3d Cir. 2018) (held blanket internet restrictions are likely overbroad after Packingham)
United States v. Perrin, 926 F.3d 1044 (8th Cir. 2019) (upheld computer restriction on supervised release post‑Packingham)