United States v. Broadfield – Do It For The Caselaw

The Seventh Circuit affirmed a district court's denial of a motion to modify supervised release conditions that prohibited a defendant with a history of alcohol abuse from consuming any alcohol. The court held that a complete ban was the least restrictive means to serve the government's compelling interest in public safety and the defendant's rehabilitation.

Background

Brian Broadfield was sentenced to prison for conspiracy to manufacture methamphetamine and placed on supervised release with a condition prohibiting alcohol use. After violating his release terms through alcohol consumption and other criminal conduct, he was reimprisoned and given a new term of supervised release. Before his release, Broadfield moved to modify the alcohol ban to allow one glass of wine during his religious Sabbath as a Messianic Jew, arguing the total ban violated the Religious Freedom Restoration Act and imposed a greater deprivation of liberty than necessary.

The court’s reasoning

The court applied the Religious Freedom Restoration Act, requiring the government to show that the burden on religious exercise is the least restrictive means of furthering a compelling interest. The court found the government had a compelling interest in protecting the community and preventing Broadfield’s recidivism given his history of binge drinking and violent behavior. The court rejected the argument that a breathalyzer or a single-glass exception would be a viable alternative, noting that Broadfield’s history showed he could not stop drinking once he started and that monitoring a single exception would be unworkable for probation officers. The court also found the condition did not involve a greater deprivation of liberty than necessary under Section thirty-five fifty-three of Title eighteen of the United States Code.

Given Broadfield’s proven history with alcohol, the danger it represents, not only to him but to everybody else around him, the district could not identify any lesser restrictive means to serve that compelling interest other than to say you can’t do this.

United States v. Broadfield, No. 25-2293, slip op. at 10 (7th Cir. June 22, 2026)

What it means going forward

The decision reinforces the authority of district courts to impose strict, total prohibitions on alcohol for supervised releasees with documented histories of addiction and violence, even when those individuals raise religious freedom claims.