US v Doyle

4-13-2013 Tennessee:

US v Doyle
No. 12-5516.

After moving to Tennessee, Rashan Doyle was charged with failure to register as a sex offender, in violation of 18 U.S.C. section 2250(a), to which he pleaded guilty without a plea agreement. The district court sentenced Doyle to three years and one month in prison followed by ten years of supervised release, upon which the district court imposed four special conditions, numbered three, four, six and eight.

Doyle appeals the district court's imposition of these four special conditions of supervised release. Because the district court erred procedurally by failing to explain its reasons for imposing the special conditions, and because the record does not otherwise illuminate the reasons for them, we VACATE the district court's imposition of the special conditions of supervised release and REMAND for resentencing proceedings consistent with this opinion.

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In conclusion, both the district court's procedural error in failing to explain its reasons for these conditions, and the record's failure to illuminate their appropriateness, require us to vacate special conditions three, four, six and eight, and to remand this case. Because we remand based upon the district court's clear error in failing to explain (or otherwise put on the record) its reasoning for imposing the special conditions of supervised release, we do not reach Doyle's constitutional arguments about the special conditions. See Lyng v. Nw. Indian Cemetery Protective Ass'n, 485 U.S. 439, 445-46 (1988) ("A fundamental and longstanding principal of judicial restraint requires that courts avoid reaching constitutional questions in advance of the necessity of deciding them.") (citations omitted).

If, in resentencing Doyle, the district court does apply special conditions of supervised release, we emphasize that "[s]upervised release conditions must be tailored to the specific case before the court." Inman, 666 F.3d at 1005. We also emphasize that, as the Court has held, "Congress intended supervised release to assist individuals in their transition to community life." United States v. Johnson, 529 U.S. 53, 58 (2000). In contrast to prison, "[s]upervised release fulfills rehabilitative ends, distinct from those served by incarceration." Id. (providing see signal for 18 U.S.C.A. § 3553(a)(2)(D)) (rest of citation omitted).

For the foregoing reasons, we VACATE special conditions numbers three, four, six and eight of Doyle's supervised release and we REMAND for resentencing proceedings consistent with this opinion.