United States v. Richard Lincoln, 876 F.3d 1137

Defendant Richard Lincoln’s supervised release was revoked after marijuana use, lying to his probation officer, and associating with a person involved in criminal activity; district court imposed six months imprisonment plus a new three‑year supervised release term.
The new supervised‑release term re‑imposed Special Condition #4 requiring mental‑health evaluation/treatment and stating it may include participation in a sex‑offender treatment program.
Lincoln did not object to or appeal Special Condition #4 when it was imposed on his original term of supervised release, and he did not object to it during subsequent re‑sentencings.
At the revocation hearing Lincoln specifically objected to re‑imposition of Special Condition #4; the court nevertheless re‑imposed it.
The PSR disclosed prior convictions for aggravated criminal sexual assault and failure to register as a sex offender; Lincoln was charged as an adult and never completed sex‑offender treatment.
The probation office identified moderate dynamic risk factors for sexual‑offense recidivism; Lincoln had begun (≈3 weeks of) a 22‑week cognitive behavioral treatment program before revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether re‑imposing Special Condition #4 (mental‑health/possible sex‑offender treatment) after revocation was reasonably related to §3553(a) factors	Special Condition #4 is not reasonably related to the nature of the revocation (drug‑related) or Lincoln’s history because the sexual misconduct was remote and he has changed	The condition is reasonably related to Lincoln’s history and rehabilitative needs given prior sexual‑offense convictions, lack of treatment, present risk factors, and the judge’s familiarity with the file	Affirmed — district court did not abuse discretion; condition reasonably related to history/rehabilitative needs
Whether Lincoln waived challenge by failing to object or appeal original imposition	Lincoln argues the condition is unlawful despite prior inaction	Government argues Lincoln waived earlier challenges by not objecting or appealing the original sentencing and re‑sentencings	Court notes waiver of some challenges but still reviews district court’s exercise of discretion on re‑imposition and affirms

United States v. Thompson, 653 F.3d 688 (8th Cir. 2011) (standard of review for supervised‑release conditions)
United States v. Godfrey, 863 F.3d 1088 (8th Cir. 2017) (§3583(d) requirements summarized)
United States v. Hart, 829 F.3d 606 (8th Cir. 2016) (broad district court discretion; consideration of §3553 factors for conditions)
United States v. Scott, 270 F.3d 632 (8th Cir. 2001) (rejecting sex‑offender condition imposed at revocation in a particular context)
United States v. Smart, 472 F.3d 556 (8th Cir. 2006) (upholding sex‑offender condition as related to defendant’s history and public safety)
United States v. Fenner, 600 F.3d 1014 (8th Cir. 2010) (affirming sex‑offender condition where rehabilitative needs and lack of treatment supported it)
United States v. Franklin, 397 F.3d 604 (8th Cir. 2005) (deference when same judge presided over related proceedings and was familiar with defendant’s history)
United States v. Carlson, 547 F.2d 1346 (8th Cir. 1976) (principle that a defendant should not benefit from their own wrongful conduct)