United States v. Bycroft
Split Score
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Case Summary
Disposition
Vacated
The Tenth Circuit held that the district court plainly erred by imposing a lifetime condition of supervised release that bars Jason Cory Bycroft from any Internet use without prior probation-officer approval. Concluding that the district court provided no on-record analysis under 18 U.S.C. § 3583(d) and that the error affected substantial rights, the panel vacated the sentence and remanded for resentencing.
Circuit Split Identified
Legal Issue
Whether an absolute (or effectively absolute) lifetime ban on Internet/computer use as a special condition of supervised release for sex-offense defendants is permissible under 18 U.S.C. § 3583(d).
Circuit Positions
Absolute or lifetime Internet/computer bans are generally impermissible absent extraordinary circumstances; the condition must be narrowly tailored and supported by on-record findings.
Absolute or lifetime Internet/computer bans are permissible for defendants convicted of sex offenses that involved computer or online activity, provided the district court enters the restriction as part of supervised release.
Conflict Summary
The Tenth Circuit generally finds an absolute Internet ban to violate § 3583(d) except in the most extreme, well-justified cases, whereas several other circuits uphold such bans more readily when the underlying offense involved child pornography or online solicitation.