Background
Luis Pineda-Zarao was convicted of a drug offense by a jury. The district court imposed a condition of supervised release related to substance abuse testing. Pineda-Zarao appealed, arguing the condition was overbroad and that he had no documented history of substance abuse.
The court’s reasoning
The court reviewed the appeal for plain error. It found no reversible plain error in the district court’s imposition of the special condition related to substance abuse testing. The court cited United States v. Jackson for the standard of review and United States v. Poitra for the principle that relief under plain error review is an exceptional remedy.
What it means going forward
The decision reinforces the district court’s discretion in imposing substance abuse testing conditions on defendants convicted of drug offenses, even absent a documented history of abuse, provided the condition does not constitute plain error.
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