United States v. Robinson
134 F.4th 104
2d Cir.2025Background
- Darrell Robinson pled guilty to being a felon in possession of firearms, in violation of 18 U.S.C. § 922(g), after police discovered six firearms in his vehicle during a warranted search.
- Robinson had a lengthy criminal record with nine prior adult convictions, including offenses involving firearms and dishonesty with law enforcement.
- The Presentence Investigation Report (PSR) recommended supervised release with a special condition permitting searches of his person, property, residence, vehicle, and electronic devices upon reasonable suspicion.
- The district court adopted the PSR's recommendations and imposed the special search condition at sentencing, though its pronouncement was general.
- After sentencing, Robinson moved to strike the electronic search condition, claiming it was not properly imposed; the court denied the motion, and Robinson appealed.
Issues
| Issue | Robinson's Argument | U.S. Government's Argument | Held |
|---|---|---|---|
| Oral pronouncement of search condition | Condition on electronics not orally imposed; only a general search condition mentioned | The reference to the PSR and adopted search condition was sufficient | Court found no error: pronouncement referencing the PSR sufficed |
| Procedural reasonableness of condition | No individualized reasons given, and no connection to electronic devices | Condition justified by Robinson's criminal history and need for supervision | Condition's necessity was self-evident; omission was harmless error |
| Fourth Amendment constitutionality | Electronic search condition overbroad & unreasonable infringement | Supervised release reduces privacy; condition is limited to reasonable suspicion | Condition is narrowly tailored and constitutional under Fourth Amendment |
Key Cases Cited
- United States v. Boles, 914 F.3d 95 (2d Cir. 2019) (standard of review for supervised release conditions)
- United States v. Washington, 904 F.3d 204 (2d Cir. 2018) (oral vs. written sentencing requirements)
- United States v. Sims, 92 F.4th 115 (2d Cir. 2024) (need for court to pronounce special release conditions)
- United States v. Rosado, 109 F.4th 120 (2d Cir. 2024) (oral pronouncement controls if conflict with written judgment)
- United States v. Betts, 886 F.3d 198 (2d Cir. 2018) (requirement to explain special conditions unless rationale is self-evident)
- United States v. Reyes, 283 F.3d 446 (2d Cir. 2002) (diminished expectation of privacy on supervised release)
- Samson v. California, 547 U.S. 843 (2006) (warrantless searches of parolees constitutional under certain conditions)