Week of February 17, 2020, through February 21, 2020
United States v. Ath (Gregory 2/21/20): The Fourth Circuit held that the government can satisfy the knowledge requirement of a drug-related conspiracy charge through circumstantial evidence of Defendant’s willful blindness. The Court affirmed the District Court for the District of South Carolina’s denial of Defendant’s motion for judgment of acquittal.
United States v. Arbaugh (Agee 2/20/20):
The Fourth Circuit held that a district court imposing special conditions of a defendant’s supervised release must adequately explain such conditions because reviewing courts must have some basis to determine whether they involve no greater deprivation of liberty than is reasonably necessary. A district court’s failure to adequately explain the conditions may result in reversible error.
In this case, Defendant, a resident of Virginia, conducted missionary work for his church in Haiti. For several years, Defendant sexually abused approximately two dozen Haitian children. Upon his return to the United States, Defendant informed a counselor that he sexually abused minor children. The counselor then reported Defendant to law enforcement. Defendant was indicted in the U.S. District Court for the Western District of Virginia on one count of knowingly traveling in foreign commence to engage in illicit sexual conduct with a minor. Defendant entered into a plea agreement and was sentenced to a term of 276 months’ imprisonment and lifetime supervised release.
On appeal, Defendant raised five challenges. These challenges related to the district court’s considerations during Defendant’s sentencing and its decision to sentence defendant to 276 months’ imprisonment. Additionally, Defendant argued that the district court failed to adequately explain its reasons for a lifetime term of supervised release and why it imposed special conditions related to Defendant’s computer usage.
The Fourth Circuit affirmed the district court’s decision to sentence Defendant to 276 months’ imprisonment and lifetime supervised release. However, the Court vacated and remanded for resentencing based on the district court’s failure to explain the four challenged special conditions of release. The Court reasoned that a district court must explain special conditions of supervised release to assure that such conditions involve no greater deprivation of liberty than is reasonably necessary. Additionally, the Court stated that a district court cannot fulfill its duty by generally referring to statutes which govern how the court should exercise its discretion in imposing special conditions of supervised release.