This legal opinion is from the United States Court of Appeals for the Eighth Circuit in the case of United States v. William Trimble, Jr. The defendant, Trimble, had been convicted of possession of child pornography and had been released from prison on supervised release. However, he violated the conditions of his release multiple times, including unauthorized internet access, viewing pornography and child pornography, and prohibited contact with minors and known sex offenders.
Trimble sought a modification of his supervised release conditions to allow him internet access without approval for attending a community college. The district court denied his request, and Trimble appealed. The Court of Appeals affirmed the district court’s decision. United States v. Trimble, 969 F.3d 853 (8th Cir. 2020) The Court explained that the district courts have the authority to modify the conditions of supervised release at any time. They reviewed the district court’s denial of Trimble’s motion to modify his release and found no abuse of discretion.
Trimble argued that the condition prohibiting internet access imposed an excessive restriction on his liberty, but the Court disagreed. They noted that Trimble’s previous revocations involved not only possessing child pornography but also having contact with minors and engaging in inappropriate behavior using electronic devices. The Court cited previous cases where they upheld internet restrictions for defendants involved in similar activities. They also emphasized that the restriction was not absolute and that Trimble’s probation officer could allow internet access for employment purposes.
Trimble also argued that the internet restriction prevented him from pursuing education, specifically attending a community college. However, the Court found that Trimble had not demonstrated sufficient progress in rehabilitation, and his previous violations undermined his trustworthiness. They noted that his probation officer was willing to consider allowing him to enroll in college if he passed a polygraph test, but Trimble had not pursued this opportunity.
Given his repeated violations and the lack of trustworthiness shown, the Court found that the district court’s decision to deny modification of the conditions was reasonable. The Court concluded that restricting Trimble’s access to the internet and electronic devices was reasonably related to his conviction and the sentencing factors. They found no abuse of discretion by the district court, and therefore affirmed the judgment.