United States v. Schaefer
675 F.3d 1122
8th Cir.2012Background
- Schaefer convicted of knowingly possessing child pornography in 18 U.S.C. §§ 2252A(a)(5)(B), 2252A(b)(2).
- District court sentenced him to 97 months’ imprisonment and 10 years’ supervised release.
- Schaefer challenges two special conditions of supervision (7 and 8).
- Court reviews special conditions for abuse of discretion under 18 U.S.C. § 3583(d).
- District court found an individualized basis, including motive to distribute pornography, supporting the conditions.
- Court affirms the two challenged conditions as reasonably related and appropriately tailored.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are the two challenged conditions validly tailored restrictions? | Schaefer argues conditions are not narrowly tailored. | Schaefer relies on Davis and argues need individualized basis. | Yes; individualized basis supports the conditions. |
| Did the district court properly conduct an individualized inquiry supporting the conditions? | Record lacks sufficient individualized findings. | Record shows motive to distribute and individualized considerations. | Record supports individualized findings and proper de novo review when needed. |
Key Cases Cited
- United States v. Springston, 650 F.3d 1153 (8th Cir. 2011) (guides deference to reasoned, individualized findings for conditions)
- United States v. Mayo, 642 F.3d 628 (8th Cir. 2011) (findings may be based on information other than false information)
- United States v. Kreitinger, 576 F.3d 500 (8th Cir. 2009) (limits on speculative or improper considerations)
- United States v. Fenner, 600 F.3d 1014 (8th Cir. 2010) (prohibition on relying on pure speculation)
- United States v. Smith, 655 F.3d 839 (8th Cir. 2011) (abuse-of-discretion review of conditions, with deference to § 3583(d) factors)
- United States v. Walters, 643 F.3d 1077 (8th Cir. 2011) (three-part abuse-of-discretion standard for conditions)
- United States v. Asalati, 615 F.3d 1001 (8th Cir. 2010) (factors for evaluating restrictions on liberty must be weighed on record)
- United States v. Kelly, 625 F.3d 516 (8th Cir. 2010) (strong caution against sweeping restrictions on constitutional rights)