Sentencing; “Supervised release”; Whether the district court violated Article III by including mental-health treatment as a condition of supervised release; Whether the district court improperly allowed the probation officer to supervise drug testing; United States v Vaughn

The court affirmed the district court’s inclusion of mental health and drug treatment as conditions of defendant-Lockridge’s supervised release, holding that Article III was not violated by the district court’s assistance from the probation department. Lockridge pled guilty to meth distribution and was sentenced to 210 months in prison and three years of supervised release. The order of supervised release contained two conditions which he challenged. The first required that he obtain mental health treatment, and the second that he be treated for substance abuse. He claimed that these requirements violated Article III’s provisions regarding district court responsibilities because a probation officer, rather than the court, oversees them. The court reviewed the parameters of Article III as it pertains to the courts’ rights to “assistance” and affirmed the probations officer’s role in Lockridge’s sentence. It affirmed the district court’s authority to “accept[], modif[y], or reject[], the nonjudicial officers’ recommendations[,]” as long as “the Article III court remains in charge.” The court held that the district court was not required to specify how the requirements were to be met or whether the mental-health treatment was to be in-patient or outpatient, especially where it would be almost two decades before Lockridge could be released. At that time, his probation officer will make recommendations and present them to the district court, which will make the decision as required under Article III. As for his objections to a probation officer deciding how many drug tests he must undergo, the court explained that it had previously held in Vaughn that a “district court may allow the probation officer to take the first pass at the number of drug tests required by a special condition, so long as the court remains free to modify that choice on its own initiative or in response to a claim by the defendant.”