United States v. Robinson

United States Court of Appeals for the Second Circuit · 2025 · Criminal Procedure

134 F.4th 104 (2025)

Updated July 27, 2026

Criminal Proceduresupervised releasespecial conditionelectronic search conditionoral pronouncementPSR incorporationprocedural reasonablenessharmless error

Facts

After law enforcement stopped and searched Robinson's vehicle pursuant to a warrant, officers found six firearms in a bag. Robinson later pleaded guilty to being a felon in possession of a firearm. The PSR recommended a single special search condition authorizing searches of Robinson's person, property, residence, vehicle, papers, computers, and other electronic devices upon reasonable suspicion of a supervised-release violation, and Robinson did not object before sentencing. At sentencing, the district court adopted the PSR's factual information, said it would rely on the PSR, and stated that "the special condition of search is obviously indicated here," after which the written judgment included the full PSR condition.

Issue

Whether the electronic-device portion of Robinson's supervised-release search condition had to be vacated because it was not adequately orally pronounced, because the district court failed to explain its reasons for imposing it, or because it unconstitutionally infringed Robinson's Fourth Amendment rights.

Rule

A district court may impose a special condition of supervised release by a clear and unambiguous reference to the condition listed in the PSR, and a written judgment does not impermissibly modify the oral sentence when it merely clarifies the spoken sentence. A district court errs if it fails to make an individualized assessment and state reasons for a special condition, but the error is harmless when the justification is self-evident in the record and the condition meets the purposes of supervised release. For a supervisee, an electronic search condition limited to reasonable suspicion that a supervised-release violation occurred and that the place searched contains evidence of that violation, and requiring searches at a reasonable time and in a reasonable manner, does not violate the Fourth Amendment given the supervisee's diminished expectation of privacy and the government's special supervisory needs.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Brooklyn, Lena Ortiz is sentenced after pleading guilty to a firearms offense. Her PSR recommends one and only one special condition: a search condition covering her person, apartment, car, papers, laptop, and phone upon reasonable suspicion of a supervised-release violation; at sentencing, the judge says he adopts and relies on the PSR and adds, "the special search condition is imposed," and the written judgment tracks the PSR exactly.

If Ortiz argues on appeal that the electronic-device portion was never orally imposed, what is the most likely result?

Explanation. A district court may impose a special condition by a clear and unambiguous reference to a condition listed in the PSR. Where the court adopted and relied on the PSR, the PSR contained only one special search condition, and the written judgment merely tracked that condition, the written judgment clarifies the oral sentence rather than impermissibly changing it.