What is the current state of the law on supervised release for a convicted sex offender?

At sentencing, the district court "may impose a condition of . . . supervised release prohibiting the defendant from engaging in a specified occupation, business, or profession . . . only if it determines that: (1) a reasonably direct relationship existed between the defendant's occupation, business, or profession and the conduct relevant to the offense of conviction; and (2) imposition of such a restriction is reasonably necessary to protect the public because there is reason to believe that, absent such restriction, the defendant will continue to engage in unlawful conduct similar to that for which the defendant was convicted." U.S.S.G. 5F1.5(a). This condition should be imposed "for the minimum time and to the minimum extent necessary to protect the public." Id. 5F1.5(b). Although district courts have "broad discretion to tailor conditions of supervised release," United States v. Gill, 523 F.3d 107, 108 (2d Cir. 2008) (per curiam) (internal quotation marks omitted), we "carefully scrutinize unusual and severe conditions, such as one

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requiring the defendant to give up a lawful livelihood," United States v. Cutler, 58 F.3d 825, 838 (2d Cir. 1995) (internal quotation marks omitted). Restrictions on a defendant's pursuit of his previous occupation may be warranted in particular "where the unlawful conduct [related to the occupation] was continued or repeated." United States v. Doe, 79 F.3d 1309, 1322 (2d Cir. 1996).