United States v. Rashan Doyle
2013 U.S. App. LEXIS 6656
| 6th Cir. | 2013Background
- Doyle moved to Tennessee and was charged with failure to register as a sex offender under 18 U.S.C. § 2250(a) and pled guilty without a plea agreement.
- District court sentenced Doyle to 3 years 1 month in prison followed by 10 years of supervised release, with four special conditions (3, 4, 6, 8).
- Presentence Report applied 2011 Guidelines, set base level 16 for Tier III offender, with potential reduction for acceptance of responsibility to 13; criminal history VI; guideline range 2:09–3:05 and supervised release at least 5 years.
- Conditions 3 forbids any pornography; condition 4 restricts contact/residence with persons under 18 and loitering near places frequented by children; condition 6 bans sexually-oriented telephone numbers or computer services; condition 8 prohibits computers with online access without prior Probation Officer approval.
- Doyle did not object at sentencing to these conditions; government and Doyle agree plain-error review applies on appeal.
- Court vacates conditions due to procedural error: the district court failed to state its reasons on the record for imposing the four conditions and the record does not illuminate the basis for them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred procedurally by failing to explain its reasons for the special conditions. | Doyle | Doyle | Yes; procedural error |
| Whether the procedural error was a plain error and affected Doyle's substantial rights. | Doyle | Doyle | Yes; plain-error preserved and prejudicial |
| Whether the error affected the fairness, integrity, or public reputation of the proceedings. | Doyle | Doyle | Yes; undermined fairness and integrity |
Key Cases Cited
- United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (plain-error review framework for improperly explained conditions)
- United States v. Adkins, 429 F.3d 631 (6th Cir. 2005) (standard for plain-error review and sentencing procedures)
- United States v. Inman, 666 F.3d 1001 (6th Cir. 2012) (requires explanation of special conditions; shows impact on substantial rights)
- United States v. Gunter, 620 F.3d 642 (6th Cir. 2010) (plain-error review standard and effect on outcomes)
- United States v. Kingsley, 241 F.3d 828 (6th Cir. 2001) (requirement to explain reasons for a sentence condition under 18 U.S.C. § 3553(c))
- United States v. Brogdon, 503 F.3d 555 (6th Cir. 2007) (procedural explanation required for special conditions)
- United States v. Berridge, 74 F.3d 113 (6th Cir. 1996) (harmless error where record shows basis for conditions)
- United States v. Lantz, 443 F. App’x 135 (6th Cir. 2011) (illustrates relation of conditions to underlying offense)
- Lyng v. Northwest Indian Cemetery Protective Ass'n, 485 U.S. 439 (1988) (avoidance of constitutional questions when not necessary)
- Bank of Nova Scotia v. United States, 487 U.S. 250 (1988) (error may affect the outcome if it may have substantial influence)
- United States v. Olano, 507 U.S. 725 (1993) (standard for determining prejudice under plain error)