United States v. Carson, No. 17–3589 (8th Cir. 2019)
Nature of Case: Appellant was convicted of federal sex offenses related to illegal images and was sentenced to a term of imprisonment as well as a lifetime supervised release term. Appellant challenged the lifetime SR term, as well as several special conditions of supervision including a condition that he be prohibited from maintaining or creating an account on any social networking site that allowed access to persons under the age of 18 (similar to restrictions that the United States Supreme Court struck down in Packingham v. North Carolina.
Holding: 8th Circuit affirmed the imposition of the SR term as well as the special conditions. The Court reasoned that because Carson would be on supervision, Packingham was distinguishable on that basis, and that the social media ban would not constitute an violation of Appellant’s constitutional rights.