United States v. Quinn, No. 12-2260 (7th Cir. 2012)
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Quinn pleaded guilty to possessing child pornography, 18 U.S.C. 2252(a)(4)(B), and was sentenced to 97 months’ imprisonment with supervised release for life, subject to conditions. His plea agreement contains a promise not to appeal the conviction or length of imprisonment. Both the Criminal Code and the Sentencing Guidelines authorize lifetime supervised release for such violations, 18 U.S.C. 3583(k); U.S.S.G. 5D1.2(b)(2) and the Sentencing Commission recommends “the statutory maximum term of supervised release” for every sex offense. While the judge explained the prison sentence, he did not address the length or conditions of supervision or address Quinn’s arguments about recidivism. The Seventh Circuit vacated and remanded with respect to supervised release. One term of supervised release prevented contact with most minors without advance approval. Quinn has a young child, whom he has never been accused of abusing. Putting the parent-child relationship under governmental supervision for long periods requires strong justification.
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