What is the current state of the law on supervised release?

MultiRegion, United States of America

The following excerpt is from United States v. Villafane-Lozada, 973 F.3d 147 (2nd Cir. 2020):

Because "[a] district court retains wide latitude in imposing conditions of supervised release," we generally review such conditions only "for abuse of discretion." United States v. MacMillen , 544 F.3d 71, 74 (2d Cir. 2008). But as "any error of law necessarily constitutes [such] an abuse," we consider legal issues de novo . Id. at 75.

Before assessing the propriety of a condition of supervision, we must assure ourselves that the defendant's challenge raises issues that are ripe for our consideration. The ripeness doctrine springs from both Article III limitations on judicial power and prudential concerns about avoiding premature judicial interference in an evolving situation. See United States v. Traficante , 966 F.3d 99, 106 (2d Cir. 2020) ; United States v. Balon , 384 F.3d 38, 46 (2d Cir. 2004). A case is ripe only when we can confidently say that "(1) the issues are fit for judicial consideration[ ] and (2) withholding of consideration will cause substantial hardship to the parties." Balon , 384 F.3d at 46 (internal quotation marks omitted); see also Abbott Laboratories v. Gardner , 387 U.S. 136, 14849, 87 S.Ct. 1507, 18 L.Ed.2d 681 (1967), abrogated on

[973 F.3d 151]

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