Background
Rafael Perdomo-Limus appealed the district court’s imposition of certain special supervised-release conditions following his guilty plea conviction for illegal reentry. He argued that the conditions were not adequately pronounced at sentencing.
The court’s reasoning
The court held that Perdomo-Limus failed to show that the district court erred, plainly or otherwise, in its oral pronouncement of his sentence. The court noted that the district court did not explicitly inquire whether he reviewed the presentence report and its appendix with counsel prior to sentencing, citing United States v. Villafana-Mondragon.
What it means going forward
The decision reinforces that defendants must demonstrate plain error to challenge the adequacy of oral pronouncements regarding supervised-release conditions.