Background
Stephen Vosilla was sentenced in 2010 to seventy months of imprisonment followed by twenty-five years of supervised release for possessing child pornography. His release conditions required him to comply with sex-offender registration laws and obtain approval before using internet-capable devices. In 2024, authorities discovered Vosilla had used unregistered email addresses and possessed gaming consoles without permission, leading to a petition to revoke his supervised release.
The court’s reasoning
The Sixth Circuit reviewed the district court’s decision de novo for legal conclusions and for abuse of discretion regarding the revocation. The court found ample evidence supported the finding that Vosilla committed new criminal offenses by failing to register email addresses as required by Tennessee law. Additionally, circumstantial evidence and Vosilla’s own admissions confirmed he possessed and used internet-capable devices without approval. The court rejected the argument that the Sony tip was inadmissible hearsay, noting that independent evidence established the violation. The district court also properly considered statutory factors and the need to protect the public when sentencing Vosilla to eighteen months of imprisonment and a new twenty-five-year term of supervised release.
there’s a strong need to protect the Emilys of the world from Mr. Vosilla
R. 159, PageID 2137
What it means going forward
The decision reinforces that supervised release conditions regarding internet access and registration compliance are strictly enforced, and violations can lead to immediate revocation and additional imprisonment.