United States v. Sealed Juvenile, 781 F.3d 747

Background

Juvenile (15) with serious mental-health diagnoses committed sexual contact with a 4‑year‑old on a military base; pleaded guilty to abusive sexual contact with a minor under 12.
Predispositional report described additional sexually inappropriate conduct (contacts with sister, sexual notes to schoolgirls, internet sexual material).
District court sentenced to 18 months in juvenile treatment center and juvenile delinquent supervision until age 21 at a non‑secure facility; imposed numerous special conditions governing contact with children, employment, loitering, and computer/Internet use/searches.
Juvenile appealed, arguing (1) the court failed to state reasons for special conditions at sentencing; (2) several conditions (contact, work, loitering, computer/Internet, searches, financial disclosures) are unrelated to § 3553(a) goals; (3) conditions are more restrictive than reasonably necessary under 18 U.S.C. § 3563(b).
Court reviewed explanation issue for plain error and specific challenged conditions for either abuse of discretion or plain error depending on objections; analysis weighed Juvenile’s offense, history, and documented internet-fueled sexual obsession.

Issues

Issue	Juvenile's Argument	Government's Argument	Held
Adequacy of court’s reasons for special conditions	Court failed to state reasons at sentencing, so conditions lack § 3553(a) justification	Written judgment contained factual findings referencing offense and mental‑health history; probation recommendation supported court	No plain error — written statement and record show consideration of § 3553(a) factors, affirming conditions
Contact restriction (no contact with <16 without permission)	Age‑16 cutoff arbitrary and overbroad; prevents interaction with siblings/peers	Juvenile has history of inappropriate conduct with children including sister and schoolgirls; protection of children outweighs association interest	Abuse of discretion not shown — condition reasonably related to risk and modifiable under § 3563(c)
Occupation restriction (no jobs with access to children without approval)	Overbroad; will impede employment opportunities for juveniles; unrelated to offense	Preventing access to children via employment is legitimate protective measure; exceptions via probation officer exist	Plain‑error standard not met — affirmed as reasonably related to protection and rehabilitation
Computer/Internet, searches, monitoring, financial disclosures	Conditions exceed necessity: overly broad internet ban, full keystroke monitoring, warrantless seizure/search, intrusive financial disclosure	Juvenile’s sexual obsession appears fueled by online material; monitoring/searches help prevent access to prohibited sexual material and aid rehabilitation	Mostly affirmed with modifications: broad prior‑approval requirement (Special Condition 13) narrowed so routine use (school, medical, work) not require prior written approval; search/monitoring conditions upheld; financial‑records condition (Special Condition 18) struck as unreasonably restrictive

Key Cases Cited

Puckett v. United States, 556 U.S. 129 (rule for plain‑error review)
United States v. Alvarado, 691 F.3d 592 (5th Cir. 2012) (plain‑error standard for sentencing challenges)
United States v. Rodriguez, 558 F.3d 408 (5th Cir. 2009) (abuse‑of‑discretion review for supervised‑release conditions)
United States v. Salazar, 743 F.3d 445 (5th Cir. 2014) (internet restrictions not reasonably related where no history linking internet to offense)
United States v. Tang, 718 F.3d 476 (5th Cir. 2013) (internet ban unrelated to failing‑to‑register offense)
United States v. Miller, 665 F.3d 114 (5th Cir. 2011) (district courts’ broad discretion setting supervised‑release conditions)
United States v. Mondragon‑Santiago, 564 F.3d 357 (5th Cir. 2009) (plain‑error guidance on sentencing articulation)
United States v. Fernandez, 776 F.3d 344 (5th Cir. 2015) (abuse of discretion where monitoring condition lacked connection to defendant’s history)