United States v. Comer, No. 19-4466 (4th Cir. 2021)
Nature of Case: Appellant was convicted of conspiring to engage in sex trafficking in federal court and was sentenced to imprisonment plus supervised release. While on supervised release she violated the conditions of her release and it was extended, and the court added a condition prohibiting her from the use of any social networking sites without prior approval from her probation officer.
Appellant sought review of these conditions as unconstitutional on a variety of grounds including void for vagueness, that it imposed a greater deprivation of liberty than necessary to accomplish the directives of supervised release, and that it represented an impermissible delegation of judicial authority.
Holding: The Fourth Circuit Court of Appeals upheld the condition of supervision as constitutional, finding that as applied to Appellant’s case the condition prohibiting her from social network use without prior approval was not void for vagueness, that it did not constitute a greater deprivation of liberty than is necessary and that it was not an impermissible delegation of judicial authority.