An Article III Conundrum? Are There Limits on How Much Authority District Courts Can Delegate to the USPO in Supervising Defendants?

 A grand jury indicted Eric Vaughn for being a felon in possession of a firearm. After he pleaded guilty, the District Court sentenced him to 53 months' imprisonment followed by three years of supervised release.

Vaughn appealed Special Conditions 1 and 2 of his supervised release, claiming both conditions improperly delegated the District Court's Article III powers to the probation officer - the former delegating the authority to determine the frequency of his drug and alcohol testing, and the later giving the probation officer the leeway to decide whether he was to undergo inpatient or outpatient mental-health treatment.  In a published opinion, the Sixth Circuit disagreed. It noted that district courts could leave the implementation of drug and alcohol testing up to probation officers when they impose testing a special - as opposed to a mandatory - condition. Since the District Court imposed testing on Vaughn as a special condition of its supervised release, the Court concluded no Article III violation occurred.

The Court similarly held that the District Court did not err in allowing the probation officer to decide whether Vaughn had to undergo inpatient or outpatient drug treatment. Noting that Vaughn had failed to object to the imposition of this condition, and that there was no binding Sixth Circuit precedent on the issue, the Court held that the District Court did not commit plain error.