United States v. Reyes-Arzate
22-320
| 2d Cir. | Oct 23, 2024Background
- Ivan Reyes-Arzate, former commander of the Sensitive Investigative Unit of the Mexican Federal Police, pled guilty to conspiracy to internationally distribute cocaine.
- Reyes-Arzate was sentenced to ten years in prison and four years of supervised release with specific conditions.
- Two challenged supervised release conditions: (1) prohibition on firearms possession, and (2) a risk-notification requirement if the probation officer and court deem him a risk.
- Reyes-Arzate appealed these conditions on constitutional grounds after pleading guilty, but did not object at sentencing.
- The appeal was heard by the Second Circuit following the Supreme Court's decisions in Bruen and Rahimi, which addressed related Second Amendment issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Firearm prohibition as supervised release condition | Reyes-Arzate: Unconstitutional per recent Second Amendment decisions (Bruen, Rahimi) | Govt: No plain error due to unsettled law and circuit split | No plain error; condition affirmed |
| Risk-notification requirement | Reyes-Arzate: Condition is vague/unconstitutional | Govt: Not ripe for judicial review | Not ripe; court did not address merits |
Key Cases Cited
- United States v. Bogle, 717 F.3d 281 (2d Cir. 2013) (affirmed constitutionality of § 922(g)(1) firearms prohibition prior to Bruen and Rahimi)
- United States v. Farooq, 58 F.4th 687 (2d Cir.) (discussed constitutionality of supervised release conditions)
- United States v. Traficante, 966 F.3d 99 (2d Cir. 2020) (addressed ripeness and vagueness of supervised release conditions)