United States v. Canfield

After pleading guilty in 2007 to possessing digital images of child pornography, 18 U.S.C. 2252A(a)(5)(B), Canfield was sentenced to 78 months of imprisonment and three years of supervised release, with conditions requiring that Canfield participate in sex offender treatment, avoid unsupervised contact with minors, and not possess “any material, legal or illegal, that contains nudity or alludes to sexual activity or depicts sexually arousing material.” While on supervised release, he violated the conditions by viewing adult pornography on unauthorized smartphones. Canfield consented to 180 days of home confinement and an additional year of supervised release. Canfield was discharged from his sex offender treatment program for smoking marijuana, holding an infant without disclosing his offender status to the infant’s mother, and for again watching adult pornography. The district court then revoked Canfield’s supervised release and sentenced him to six months’ imprisonment, followed by five more years of supervised release. The Seventh Circuit vacated three special supervised release conditions: a requirement that he notify third parties about the risks his offender status poses; a condition that he undergo drug testing and substance abuse treatment at the direction of his probation officer; and a prohibition on all access to sexually explicit material. The court upheld a ban on using the Internet to access sexually explicit material. View "United States v. Canfield" on Justia Law