United States v. Steven Zinnel, 19-10159

Steven Zinnel was convicted of multiple offenses arising from a lengthy bankruptcy-fraud and money‑laundering scheme, including violations of 18 U.S.C. §§ 152(7), 152(1), 1956(a)(1)(B)(i), 1957, and 1956(h).
The district court calculated a Guidelines range of 188–235 months but varied downward and imposed a 152‑month imprisonment term and three years of supervised release.
The district court relied on the scope and duration of the fraud, significant victim loss, and involvement of family/friends when explaining the sentence; the presentence report documented post‑indictment excessive alcohol use.
Zinnel appealed only his sentence and supervised‑release conditions, and also sought reassignment alleging judicial bias; the government conceded that two standard supervised‑release conditions (4 and 12) were unconstitutionally vague.
The Ninth Circuit affirmed in part, vacated in part, and remanded for resentencing: it upheld the procedural and substantive reasonableness of the sentence (except for one supervised‑release condition), vacated conditions 4 and 12 as facially vague, vacated standard condition 8 (no contact with life partner) for insufficient justification, and upheld a no‑alcohol special condition.
Judge Bress dissented in part, arguing the district court made sufficient findings to impose the no‑contact condition with the life partner.

Issue	Zinnel's Argument	Government's Argument	Held
Procedural error in sentencing	District court failed to properly consider disparity evidence and adequately explain sentence	Court sufficiently considered arguments, explained sentencing factors	No procedural error (except condition 8 and vagueness issues)
Substantive reasonableness of 152‑month sentence	152 months is substantively unreasonable despite below‑Guidelines variance being small	152 months is a meaningful 36‑month variance below Guidelines and supported by reasons	Sentence substantively reasonable; affirmed
Vagueness of supervised‑release standard conditions 4 & 12	Conditions are vague and unconstitutional under controlling Ninth Circuit law	Government concedes vagueness	Conditions 4 and 12 vacated and remanded for modification consistent with Evans line of cases
Standard condition 8 (ban on contact with life partner)	Ban unlawfully burdens a significant associational liberty interest; court failed to show necessity	District court said condition was reasonably related to public protection	Vacated and remanded: court must explain why ban is "necessary" and not greater than required (enhanced procedural showing required)

United States v. Carty, 520 F.3d 984 (9th Cir. 2008) (abuse‑of‑discretion standard and sentencing reasonableness principles)
United States v. Treadwell, 593 F.3d 990 (9th Cir. 2010) (disparity among unrelated defendants is not evidence of unwarranted disparity)
United States v. Laurienti, 731 F.3d 967 (9th Cir. 2013) (district court must set forth enough explanation to show consideration of parties’ arguments)
United States v. Bendtzen, 542 F.3d 722 (9th Cir. 2008) (below‑Guidelines sentences are generally reasonable when supported by district court reasoning)
United States v. Evans, 883 F.3d 1154 (9th Cir. 2018) (standard supervised‑release conditions can be unconstitutionally vague)
United States v. Ped, 943 F.3d 427 (9th Cir. 2019) (post‑Evans guidance on modifying vague conditions)
United States v. Betts, 511 F.3d 872 (9th Cir. 2007) (upholding alcohol‑prohibition condition when evidence of substance problems exists)
United States v. Wolf Child, 699 F.3d 1082 (9th Cir. 2012) (enhanced procedural requirements and necessity showing for associational bans)
United States v. Stoterau, 524 F.3d 988 (9th Cir. 2008) (conditions must not impose greater deprivation of liberty than necessary)
Medrano v. City of Los Angeles, 973 F.2d 1499 (9th Cir. 1992) (factors for reassignment and "unusual circumstances")