United States v. Worley, No. 11-4348

Decided:  July 13, 2012

This case involved a criminal defendant’s appeal of his 100-month sentence and special conditions imposed on his supervised release.  The Fourth Circuit affirmed the 100-month sentence, reversed the district court’s imposition of certain special conditions, and vacated and remanded the case for further proceedings on additional special conditions.

Defendant David Michael Worley was indicted on federal methamphetamine charges, including conspiracy to manufacture, possess, and distribute an unspecified quantity of methamphetamine and other related charges.  In addition to sentencing Worley to 100 months, the district court imposed fifteen special conditions on Worley’s three-year term of supervised release which were set forth in a standing order in the Western District of Virginia for federal sex-offense conditions.

On appeal, Worley challenged the district court’s imposition of federal tier II sex offender conditions based on his prior record as a sex offender.  The Fourth Circuit found that the district court plainly erred in imposing restrictions that apply to defendants sentenced for federal sex offenses because Worley’s drug-related offense was not a sex offense.  The Fourth Circuit accepted the Eighth Circuit’s reasoning in United States v. Davis, 452 F.3d 991, 995-96 (8th Cir. 2006), that “conditions that interfere with a defendant’s constitutional liberties, such as raising his child or associating with a loved one, must be adequately explained or else their imposition undermines the fairness and integrity of our judicial pleadings.”  Therefore, it found plain error in the district court’s imposition of restrictions affecting Worley’s relationship with his family in the absence of any explanation.  Accordingly, the Fourth Circuit reversed the district court’s imposition of three special conditions.

Next, the Fourth Circuit vacated remaining conditions and remanded them to the district court for further proceedings, finding insufficient evidence in the record to support the conditions.  Finally, the Fourth Circuit found the district court’s explanation in support of its 100-month sentence to be sufficient and upheld it as “procedurally and substantively reasonable.”

Full Opinion

– Allison Hite

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