Lexplug logoLexplug

United States of America v. Charles Goodwin

United States Court of Appeals for the Seventh Circuit
Appeal from the United States District Court for the Central District of Illinois. No. 2:11-cr-20036-RM-BGC-1—Richard Mills, Judge. (2013)
ELI5:

Rule of Law:

The delegation of authority to the Attorney General under the Sex Offender Registration and Notification Act (SORNA) to apply its requirements to pre-enactment offenders is constitutional because it is guided by an intelligible principle. Additionally, special conditions of supervised release must be vacated if they are imposed without on-the-record justification linking them to the defendant's offense, history, and characteristics, and ensuring they are not a greater deprivation of liberty than reasonably necessary.


Facts:

  • In 1994, Charles Goodwin was convicted in Florida for an attempted lewd and lascivious act involving a child.
  • In December 2006, Goodwin was convicted in Illinois for failing to register as a sex offender.
  • In August 2007, Goodwin registered as a sex offender in Illinois, but by October 2007, he had moved to Florida and registered there.
  • Goodwin failed to re-register in Florida in April 2008 as required.
  • After being arrested for this failure in July 2008 and re-registering, Goodwin moved from Florida back to Illinois in September 2008.
  • Upon moving to Illinois, Goodwin failed to register in that state, and he also failed to appear for a court date and re-register in Florida in October 2008.

Procedural Posture:

  • A federal grand jury indicted Charles Goodwin for knowingly failing to register as a sex offender under SORNA.
  • Goodwin pleaded guilty to the charge in the U.S. District Court for the Central District of Illinois.
  • A probation officer prepared a Presentencing Report (PSR) which calculated an advisory Sentencing Guidelines range of five years to life for supervised release.
  • The district court sentenced Goodwin to 27 months' imprisonment, followed by a life term of supervised release subject to ten special conditions.
  • Goodwin appealed his conviction and sentence to the U.S. Court of Appeals for the Seventh Circuit.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the provision of the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. § 16913(d), which grants the Attorney General the authority to apply the Act's registration requirements to sex offenders convicted before its enactment, constitute an unconstitutional delegation of legislative power?


Opinions:

Majority - Tinder, Circuit Judge

No, the provision of the Sex Offender Registration and Notification Act (SORNA) granting the Attorney General authority to apply its requirements retroactively does not constitute an unconstitutional delegation of legislative power. A delegation is constitutional if Congress provides an 'intelligible principle' to guide the executive's discretion. Here, SORNA meets the three requirements for a valid delegation: (1) it delineates a general policy of protecting the public and establishing a comprehensive registry; (2) it identifies the Attorney General as the public agency to apply it; and (3) it sets clear boundaries on the delegated authority, limiting it to the narrow question of retroactivity. The court's precedent in United States v. Dixon confirms this conclusion. However, the court found plain error in Goodwin's sentence. The district court incorrectly calculated the advisory Guidelines range for supervised release and imposed a life term based on this error. Furthermore, the court vacated several special conditions of supervised release—including those related to computer monitoring, contact with minors, and possession of sexually arousing material—because the district court failed to provide any justification demonstrating that they were reasonably related to Goodwin's offense or history and did not involve a greater deprivation of liberty than necessary.



Analysis:

This decision reaffirms the highly deferential modern standard for the nondelegation doctrine, illustrating that broad congressional goals like 'protecting the public' are sufficient to serve as an 'intelligible principle.' The ruling solidifies that so long as Congress confines the scope of delegated authority, the guidance for exercising that authority can be minimal. In the sentencing context, the opinion serves as a significant procedural check on district courts, mandating that they create a clear, on-the-record justification for each special condition of supervised release. This holding strengthens defendants' ability to challenge boilerplate or overly broad conditions that are not tailored to their specific offense and characteristics, particularly when those conditions impinge on fundamental liberties.

G

Gunnerbot

AI-powered case assistant

Loaded: United States of America v. Charles Goodwin (2013)

Try: "What was the holding?" or "Explain the dissent"