Seventh Circuit - Supervised Release

United States v. Lee, 950 F.3d 439 (7th Cir. 2020). A clause in a condition of supervised release requiring the defendant to obtain permission from the probation officer before knowingly associating with felons improperly delegated the court’s authority to the probation officer. The clause did not involve “management or supervision” of a condition, it involved whether a condition of supervised release should go into effect.

United States v. Hogenkamp, 979 F.3d 1167 (7th Cir. 2020). A court may modify supervised release conditions before a defendant’s release from prison. The court erred in denying as premature an incarcerated defendant’s motion to modify those conditions.

United States v. Strobel, 987 F.3d 743 (7th Cir. 2021). The written judgment, which contained supervised release conditions that were in the presentence report but were not announced at the sentencing, did not conflict with the oral pronouncement of the sentence. The defendant “had ample notice and had no objection at sentencing [] to any of the conditions of supervised release.”

United States v. Teague, 8 F.4th 611, (7th Cir. 2021). Upon revocation of supervised release, the court was not obliged to apply the statutory minimum term of supervised release that applied at the original sentencing. Concluding otherwise was plain error because 18 U.S.C. § 3583(h) provides only that the “court may include” a new term of supervised release upon revocation of a previous term of supervision.

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