United States v. Brian Broadfield

• Court: Court of Appeals for the Seventh Circuit
• Decided: June 22, 2026
• Docket: 25-2293
• Status: Published
• Author: Pryor

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ No. 25-2293 UNITED STATES OF AMERICA, Plaintiff-Appellee, v.

BRIAN BROADFIELD, Defendant-Appellant. ____________________

Appeal from the United States District Court for the Central District of Illinois. No. 13-cr-10055-1 — Michael M. Mihm, Judge. ____________________

ARGUED MAY 21, 2026 — DECIDED JUNE 22, 2026 ____________________

Before KIRSCH, PRYOR, and MALDONADO, Circuit Judges. PRYOR, Circuit Judge. After serving a prison term for con- spiracy to manufacture methamphetamine, Brian Broadfield violated the terms of his supervised release in June 2024. For doing so, the district court adjudicated Broadfield guilty and imposed a term of 16 months’ imprisonment and imposed six years of supervised release. United States v. Broadfield, No. 24- 2075, 2025 WL 667522, at *2 (7th Cir. Mar. 3, 2025). A condition 2 No. 25-2293

of supervised release required Broadfield to “refrain from any use of alcohol.” About a month before completing his prison term, Broad- field moved to modify the conditions of his supervised re- lease. Broadfield argued that he should be permitted to drink a glass of wine during a religious ceremony on his Sabbath, which is sundown Friday to sundown Saturday, in accord- ance with his religious beliefs as a Messianic Jew. In his view, the complete alcohol ban ran afoul of his rights under the Re- ligious Freedom Restoration Act (“RFRA”), 42 U.S.C. § 2000bb et seq., and involved a greater deprivation of liberty than was reasonably necessary for the purposes set forth in 18 U.S.C. § 3553(a). While this motion was pending, Broadfield began serving his term of supervised release. The district court eventually denied Broadfield’s request for the modification, and Broad- field appeals. For the reasons articulated below, we affirm. I. BACKGROUND A. Factual and Procedural History In 2013, Broadfield was indicted with conspiracy to man- ufacture methamphetamine in violation of 21 U.S.C. §§ 841(a)(1), (b)(1)(B), and 846. Broadfield pled guilty pursu- ant to a plea agreement to conspiracy to manufacture meth- amphetamine in 2014. Prior to sentencing, Broadfield moved for an independent psychological evaluation, which the dis- trict court granted. The report concluded with reasonable medical certainty that Broadfield suffered from various psychiatric disorders, including alcohol use disorder and several substance abuse disorders. As stated in the report, Broadfield reported losing No. 25-2293 3

control of his use of alcohol and that his binging of alcohol contributed to his criminal convictions and social isolation. The report also provided treatment recommendations, in- cluding that Broadfield would benefit from medication, psy- chotherapy, and “rehabilitation efforts to maintain abstinence from drugs and alcohol.” Indeed, the report noted, “[a]bsti- nence should be the goal.” Prior to sentencing, the United States Probation Office submitted its Presentence Investigation Report (“PSR”). The PSR detailed that during Broadfield’s late teens and in his twenties, he received two convictions under state law for driving under the influence and one conviction for burglary where he revealed he was intoxicated during the offense. 1 It also described that Broadfield’s abuse of drugs and alcohol thwarted successful completion of his terms of probation for his various state convictions. And by his early thirties, the PSR reported that Broadfield had accumulated numerous convic- tions regarding the possessing and manufacturing of meth- amphetamine. In March 2016, the district court sentenced Broadfield to a below-Guidelines sentence of 208 months’ imprisonment to be followed by eight years of supervised release. A condition of his supervised release was that he refrain from the use of alcohol, and Broadfield did not object. Following a motion

1 Prior to his federal indictment for the instant offense, Broadfield had also been separately convicted of burglary, forgery, unlawful use of a credit card, attempted theft, criminal damage to property, obstructing justice three times, attempted obstruction of justice, resisting a peace officer, and possession of cannabis. 4 No. 25-2293

from the government, the district court later reduced Broad- field’s prison sentence to 156 months and entered an amended judgment on May 5, 2017. B. Supervised Release Violations

Broadfield began his term of supervised release on No- vember 17, 2023. A few days later, on November 27, 2023, Broadfield submitted to drug and alcohol testing, which re- turned positive for alcohol metabolite. In December, Broad- field admitted to his probation officer that he had consumed alcohol and was verbally admonished. And, in March 2024, Broadfield failed to submit to a random drug test and admit- ted to a supervisory probation officer that he had begun using marijuana. He was again admonished by probation on March 20, 2024. Then, about a week later, frustrated with his girlfriend, Broadfield started drinking alcohol. He continued until he had drunk an entire bottle of liquor and “blacked out.” He had a physical and verbal altercation with his girlfriend to which police responded. The police ultimately arrested Broadfield. While in the police car, he slipped his handcuffs to the front of his body, attempted to rip the car’s camera down, and tried to damage the car’s window and divider with his foot. The police deployed pepper spray to stop Broad- field’s behavior. While in the holding shower cell at the jail that same day, he began flooding the cell. He was removed and escorted to a different cell. Once there, he hit and kicked the cell door, urinated on the floor, and shoved feces under the door. He ultimately fell asleep, woke up, and apologized to jail staff. No. 25-2293 5

Based on these events, Broadfield was charged in state court with domestic battery and resisting arrest. And, on April 1, 2024, the United States Probation Office for the Cen- tral District of Illinois filed a petition to revoke Broadfield’s supervised release. The petition alleged Broadfield commit- ted domestic battery, resisting arrest, and two charges of criminal damage to government property in violation of a condition of his supervised release prohibiting him from com- mitting another crime. The petition also alleged Broadfield vi- olated other terms and conditions, including a condition pro- hibiting his possession or use of alcohol and a condition re- quiring him to report a change of address. A warrant was is- sued in connection with the revocation petition, and Broad- field was arrested on April 8, 2024. A magistrate judge held a detention hearing on April 10, 2024, and ordered Broadfield detained pending resolution of the probation office’s petition to revoke his supervised re- lease. C. Revocation of Supervised Release At the revocation hearing in June 2024, Broadfield admit- ted the violations of supervised release, including resisting ar- rest, two counts of criminal damage to property, failure to comply with mental health treatment, possessing and con- suming alcohol, and failure to report a change in address. Broadfield, 2025 WL 667522, at *1. The government withdrew its allegation that Broadfield’s conduct constituted domestic battery. During the hearing, defense counsel explained to the dis- trict court that Broadfield “has this generalized anxiety disor- der … . And if he gets into a real stressful situation, his mind 6 No. 25-2293

gets racing. It gets the better of him. He makes poor decisions. One of the poor decisions he makes is to turn to alcohol to try and slow that down.” When Broadfield’s anxiety increases, defense counsel stated, “[Broadfield] drinks. And he doesn’t just drink alone [sic]. He drinks the entire bottle. And … that’s why he’s here.” Defense counsel continued by noting that Broadfield’s “mental illness” coupled with his alcohol use was an “unfortunate[] … fact of his life that he need[ed] to address.” Indeed, defense counsel emphasized that Broad- field had a dual diagnosis of mental illness and substance abuse, requiring integrated treatment that intertwined. Thus, he concluded, Broadfield “can’t use alcohol because … once he starts, he can’t stop.” The district court echoed that sentiment prior to announc- ing its decision to impose a term of reimprisonment for Broad- field. Specifically, it emphasized that Broadfield suffered from “mental health problems” that he refused to acknowledge as well as his need for mental health treatment. The district court also adopted the factual findings outlined in the probation office’s supplemental violation report, which highlighted Broadfield’s history of alcohol abuse, mental health issues, crimes involving alcohol, and illegal drug use. Moreover, the district court adopted the applicable sentenc- ing guidelines range calculation that the document laid out of 21 months to 27 months’ imprisonment for Broadfield’s of- fense. For violating his supervised release, the court sentenced Broadfield to a below-Guidelines’ sentence of 16 months’ im- prisonment to be followed by six years of supervised release. The court imposed as a condition of supervised release that Broadfield “refrain from any use of alcohol” and “participate No. 25-2293 7

in a program for alcohol treatment,” “including testing, to de- termine if [he had] used alcohol.” Broadfield did not object to this condition. D. Motion to Modify Conditions of Supervised Release About a month before being released from prison, in April 2025, Broadfield moved to modify his conditions of super- vised release. Broadfield asserted the complete alcohol ban burdened his right as a practicing Messianic Jew to exercise his faith of con- suming alcohol during religious ceremonies on his Sabbath. 2 Thus, in his view, the alcohol prohibition condition substan- tially burdened his exercise of religion in violation of RFRA and involved a greater deprivation of liberty than reasonably necessary to accomplish the goals of § 3553(a). Broadfield con- ceded that the government had a compelling interest in his compliance with the conditions of his supervision and the ban on alcohol furthered that interest. But he maintained the com- plete alcohol ban, with no exception for religious observance, was not the least restrictive means of furthering the govern- ment’s interest. The government opposed the motion, arguing the com- plete ban was the least restrictive means to further its interest of protecting the public and involved no greater deprivation

2 Broadfield also moved to modify a condition of his supervised release that he “take any and all prescribed medications recommended by” men- tal health treatment providers. The district court modified that condition to require Broadfield to take any prescribed medication unless he notified the court that he did not want to take it, at which point the court would hold a hearing. Broadfield raises no issue on appeal regarding the district court’s decision on that front, so we discuss it no further. 8 No. 25-2293

of liberty than was necessary for the purposes laid out in 18 U.S.C. § 3553(a). The district court held a hearing on Broadfield’s motion. At the hearing, Broadfield narrowed his request and empha- sized that he was seeking only to be allowed to drink “a nor- mal wineglass amount of wine” during a religious ceremony that occurred on his Sabbath. Put another way, Broadfield was seeking to modify the condition of his supervised release to provide that he be banned from consuming alcohol save for one glass of wine during a religious ceremony on his Sabbath. The government explained, however, that permitting al- cohol use even during his Sabbath would thwart probation’s effective monitoring of Broadfield’s overall compliance with the condition because the urinalysis test probation used only tested for the presence of alcohol metabolite. That meant the test could only return a positive result (alcohol was present) or a negative result (alcohol was absent). Though the govern- ment suggested it might agree to Broadfield’s request if pro- bation could successfully monitor the single glass of wine “was the only alcohol that was being consumed,” the govern- ment contended that it would not be possible and “any excep- tion would greatly decrease[] probation’s effectiveness” in en- suring compliance “with this condition that he not drink al- cohol.” The government also insisted Broadfield’s abstention from drinking alcohol was necessary to further its compelling interest in public safety. In response, defense counsel argued probation could use a breathalyzer to monitor Broadfield’s compliance with the condition and the requested exception—even though he rec- ognized that he did not know if they would be sensitive enough “for evidentiary purposes.” In his view, though, that No. 25-2293 9

option provided a more tailored solution to advance the gov- ernment’s compelling interest and minimize the burden on Broadfield’s religious rights. The district court denied Broadfield’s motion. The district court explained that Broadfield “is dangerous when he drinks,” “doesn’t deal with stress well,” and had “serious,” drinking habits. Because of that, the district court found the government demonstrated a compelling interest in keeping Broadfield alcohol free. Given Broadfield’s history, the dis- trict court found drinking a single glass of alcohol could cause Broadfield to “go off the deep end.” The district court then queried whether it could “some- how protect against that” for Broadfield. Analyzing the par- ties’ arguments, the sentencing judge did not see how it could enforce a condition that banned Broadfield from drinking al- cohol except for a single glass of wine that could be consumed only during a religious ceremony on his Sabbath. The use of a breathalyzer was not a solution because it was unworkable in the district court’s view. Probation was “not going to … follow him around until” his religious ceremony or be unrea- sonably forced to “[make] arrangements to go to his religious ceremony with him and test him right after it’s over.” Even more to the point, however, “the only way to reasonably im- pose [the] condition,” the district court continued, “is to say that he cannot drink alcohol, period.” Given Broadfield’s “proven history with alcohol, the danger it represents, not only to him but to everybody else around him,” the district could not identify any lesser restrictive means to serve that compelling interest “other than [to] say you can’t do this.” Ac- cordingly, the district court denied Broadfield’s request to modify this condition of his supervised release. 10 No. 25-2293

Broadfield now appeals. 3 II. ANALYSIS On appeal, Broadfield lodges two challenges to the denial of his motion to modify his supervised release conditions. First, he argues the complete alcohol ban violates RFRA be- cause it is not the least restrictive means to advance the gov- ernment’s compelling interest. Second, Broadfield presses that the complete alcohol ban is a greater deprivation of lib- erty than is reasonably necessary to achieve the goals outlined in § 3553(a). Before moving to the analysis, we provide some proce- dural context. When imposing a term of supervised release, a district court must include certain mandatory conditions, such as forbidding the defendant from committing another crime. 18 U.S.C. § 3583(d); see also Esteras v. United States, 606 U.S. 185, 188 (2025) (“Supervised release comes with condi- tions—for instance, the defendant must refrain from commit- ting another crime.” (citing 18 U.S.C. § 3583(d)). The court may also impose others within its discretion. Esteras, 606 U.S. at 192; 18 U.S.C. § 3583(d). A discretionary condition of super- vised release may include prohibiting a defendant from con- suming alcohol. See, e.g., United States v. Schave, 186 F.3d 839, 842 (7th Cir. 1999) (collecting cases). When a court decides

3 While certain of our sister circuits have held that district courts lack ju- risdiction over a defendant’s challenge to the legality of a condition of su- pervision via a motion to modify the conditions of supervised release un- der 18 U.S.C. § 3583, see, e.g., United States v. Faber, 950 F.3d 356, 359 (6th Cir. 2020) (collecting cases), we have long held the opposite, United States v. Neal, 810 F.3d 512, 518 (7th Cir. 2016). That is, “§ 3583(e)(2) … allow[s] a defendant to bring substantive challenges to the current legality of condi- tions of supervised release.” Id. With that, our jurisdiction is secure. Id. No. 25-2293 11

both to include a term of supervised release and the condi- tions of such a term, it must consider the factors set forth in a variety of statutory provisions. Esteras, 606 U.S. at 192; 18 U.S.C. § 3583(d)(1)–(3). A defendant can move to modify his conditions of super- vised release, and the district court “must hold a hearing, at which the person has the right to counsel and an opportunity to make a statement and present information in mitigation.” FED. R. CRIM. P. 32.1(c). “Any modification, like the original conditions, must (1) be ‘reasonably related to the factors iden- tified in § 3553(a), including the nature and circumstances of the offense and the history and characteristics of the defend- ant; (2) involve no greater deprivation of liberty than is rea- sonably necessary for the purposes set forth in § 3553(a); and (3) [be] consistent with the policy statements issued by the Sentencing Commission.’” United States v. Evans, 727 F.3d 730, 733 (7th Cir. 2013) (quoting United States v. Ross, 475 F.3d 871, 873 (7th Cir. 2007)). In addition to the nature and circumstances of the offense and the history and characteristics of the defendant, any mod- ification must also be reasonably related to affording ade- quate deterrence to criminal conduct, protecting the public from further crimes of the defendant, and providing the de- fendant with needed educational or vocational training, med- ical care, or other correctional treatment in the most effective manner. United States v. Martin, 109 F.4th 985, 989–90 (7th Cir. 2024); 18 U.S.C. § 3583(e) (citing 18 U.S.C. § 3553(a)(1), (a)(2)(B)–(D)). The district court in making its modification decision must also consider the kinds of sentences available, pertinent policy statements issued by the United States Sen- tencing Commission, the need to avoid unwarranted sentence 12 No. 25-2293

disparities among defendants with similar records who have been found guilty of similar conduct, and the need to provide restitution to any victims of the offense. 18 U.S.C. § 3583(e) (citing 18 U.S.C. § 3553(a)(4)–(7)). With respect to our standard of review, we examine a dis- trict court’s denial of a motion to modify conditions of super- vised release for an abuse of discretion. United States v. Baker, 755 F.3d 515, 523 (7th Cir. 2014); Evans, 727 F.3d at 732. But when evaluating the legality of a condition of supervised re- lease turns on an “an analysis of constitutional issues,” our review is de novo. United States v. Israel, 317 F.3d 768, 770 (7th Cir. 2003); see also United States v. Shannon, 851 F.3d 740, 743 (7th Cir. 2017). A. Application of the Religious Freedom Restoration Act We turn now to Broadfield’s first argument. He contends, as a practicing Messianic Jew, the district court’s supervised release condition prohibiting him from the use of alcohol vio- lates his free exercise of religion, in violation of RFRA. Under RFRA, the federal government is prohibited “from taking any action that substantially burdens the exercise of re- ligion unless that action constitutes the least restrictive means of serving a compelling government interest.” Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682, 690–91 (2014); 42 U.S.C. § 2000bb–2000bb-4. Put another way, “[o]nce a RFRA claim- ant makes a prima facie case that the application of a law or regulation substantially burdens his religious practice, the burden shifts to the government to justify the burden under strict scrutiny.” Korte v. Sebelius, 735 F.3d 654, 673 (7th Cir. 2013). No. 25-2293 13

The parties here do not dispute that Broadfield holds a sin- cerely held religious belief that the complete alcohol ban con- dition of supervised release substantially burdens. So the only question in this appeal is whether the government has demonstrated that this condition furthers a compelling gov- ernmental interest and the total ban is the least restrictive means of furthering that interest. Hobby Lobby, 573 U.S. at 694– 95. Broadfield argues that to conform with RFRA’s religious liberty protections, however, this condition must be modified to allow him, a Messianic Jew, to drink one glass of wine dur- ing a religious ceremony between sundown on Friday and sundown on Saturday in accordance with his sincerely held religious belief. 1. Compelling Interest “[U]nder RFRA … the government must establish a com- pelling and specific justification for burdening [the objecting party].” Korte, 735 F.3d at 685. That is, “RFRA requires the [g]overnment to demonstrate that the compelling interest test is satisfied through application of the challenged law ‘to the person’—the particular claimant whose sincere exercise of re- ligion is being substantially burdened.” Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418, 430–31 (2006). To frame the compelling interest properly, we must ask whether the government’s particular interest in burden- ing Broadfield’s right, as a practicing Messianic Jew to drink a glass of wine during a religious ceremony on his Sabbath, is justified in light of the record. West v. Radtke, 48 F.4th 836, 848 (7th Cir. 2022). Here, Broadfield concedes that the government has a com- pelling interest in preventing him from using alcohol outside his religious services. But the government goes further, 14 No. 25-2293

contending that it has a compelling interest in prohibiting Broadfield from consuming alcohol entirely. We agree. First, the Supreme Court has made clear that the govern- ment has a compelling interest in protecting the community from the criminal acts of another. Schall v. Martin, 467 U.S. 253, 264 (1984) (recognizing that the government has a “‘legitimate and compelling interest’ in protecting the community from crime” (quoting De Veau v. Braisted, 363 U.S. 144, 155 (1960))). Second, the government has a compelling interest in curbing an individual’s recidivism, promoting his rehabilitation, and preventing drug abuse. Israel, 317 F.3d at 771; United States v. Widmer, 785 F.3d 200, 204 (6th Cir. 2015); see also Kaemmerling v. Lappin, 553 F.3d 669 (D.C. Cir. 2008). These compelling interests apply in full force to Broad- field. Broadfield has a sustained record of alcohol abuse closely linked to his commission of crimes and other violent behavior. He has been arrested twice for driving under the influence, committing burglary while intoxicated, and violat- ing the terms and conditions of his supervised release sparked by his binge drinking. His most recent violations, which led to the June 2024 revocation and prison term, were initiated by his consumption of a bottle of moonshine in one sitting and “blacking out.” Broadfield himself has acknowl- edged that imbibing alcohol has prompted criminal activity, hindered his successful completion of supervision, and led to other regretful behavior. Given all of this, we agree with the district court that the government has a compelling interest in keeping Broadfield alcohol free. No. 25-2293 15

2. Narrow Tailoring For its part, the “least restrictive means” prong is “excep- tionally demanding” and requires the government to “show that ‘it lacks other means of achieving its desired goal without imposing a substantial burden on the exercise of religion by the objecting part[y].’” West v. Hoy, 126 F.4th 567, 573 (7th Cir. 2025) (alteration in original) (quoting Hobby Lobby, 573 U.S. at 728); see also Korte, 735 F.3d at 686 (evaluating RFRA claims “requires a substantial congruity—a close ‘fit’—between the governmental interest and the means chosen to further that interest”). When faced with a “viable alternative,” the govern- ment must show why, with evidence, it will not achieve its desired goal. Hobby Lobby, 573 U.S. at 728–29; Holt v. Hobbs, 574 U.S. 352, 369 (2015) (noting that courts cannot “assume a plausible, less restrictive alternative would be ineffective” (quoting United States v. Playboy Ent. Grp., Inc., 529 U.S. 803, 824 (2000))); O’Bryan v. Bureau of Prisons, 349 F.3d 399, 401 (7th Cir. 2003) (“A governmental body that imposes a ‘substantial’ burden on a religious practice must demonstrate, and not just assert, that the rule at issue is the least restrictive means of achieving a compelling governmental interest.” (emphasis in original)). And like the compelling interest prong, RFRA “re- quir[es] the [g]overnment to demonstrate that application of a substantial burden to the person … is the least restrictive means of furthering [that] compelling governmental inter- est.” Hobby Lobby, 573 U.S. at 728 (emphasis in original) (quot- ing 42 U.S.C. § 2000bb-1(b)). On this front, the parties’ arguments flow from their re- spective framing of the government’s compelling interest in this case. Broadfield insists that there is a least restrictive means to advance the government’s compelling interest in 16 No. 25-2293

keeping him alcohol free but for a single glass of wine im- bibed during a religious ceremony on his Sabbath. In his view, a probation officer could use a breathalyzer to monitor his drinking as opposed to the urinalysis test, which only tests for the presence or absence of alcohol metabolite. The govern- ment disagrees. In its view, the only way to advance its com- pelling interest in preventing Broadfield from committing crimes while intoxicated, to promote his rehabilitation, to re- duce his recidivism, and to curb his alcohol addiction is to for- bid him from drinking alcohol without any exceptions. And even if we accepted Broadfield’s framing of the compelling interest here, the government maintains that forcing a proba- tion officer to follow Broadfield around with a breathalyzer is impracticable and would impose significant administrative burdens on the probation office. Looking at Broadfield’s history and characteristics, we agree with the district court that a complete alcohol ban is the least restrictive means to advance the government’s compel- ling interest. See, e.g., United States v. Anderson, 854 F.3d 1033, 1037 (8th Cir. 2017) (“[W]e see no way for the [g]overnment to accommodate [the defendant] while still furthering its in- terests.”); United States v. Christie, 825 F.3d 1048, 1063 (9th Cir. 2016) (“[I]n this case, in light of these defendants and the facts in this record, we are convinced that the government could not achieve its compelling interest … through anything less than mandating the [defendants’] full compliance with the [applicable law].”). The record here is replete with evidence supporting this conclusion. Multiple medical professionals have diagnosed Broadfield with alcohol addiction or depend- ence and advocated that he abstain from alcohol. Broadfield himself has admitted to losing control of his use of alcohol, typically being intoxicated when he engages in criminal No. 25-2293 17

behavior, and drinking too much too fast. Broadfield’s lawyer at his revocation hearing argued Broadfield should not be permitted to drink because once Broadfield starts, he cannot stop. Against this evidentiary backdrop, Broadfield contends nothing in the record shows he is dangerous when he drinks a single glass of wine as opposed to when he drinks in excess. This record, which provides evidence spanning most of Broadfield’s life, shows the opposite. Indeed, the events un- derlying the revocation of his supervised release illustrate why a complete alcohol ban is narrowly tailored. Broadfield’s first sip of liquor snowballed into him consuming a whole bottle of liquor, spurring charges of resisting arrest and crim- inal destruction of government property. Nothing less than a complete ban advances the government’s compelling and particularized interest in preventing Broadfield from slipping down this slope again. At bottom, the government has borne its burden. The evi- dence here shows that completely prohibiting Broadfield from consuming alcohol is the least restrictive means to fur- ther the government’s compelling interest in protecting the community from him, preventing his recidivism, promoting his rehabilitation and successful completion of supervised re- lease, and treating his alcoholism. For that reason, we need not opine on whether monitoring Broadfield’s alcohol use 18 No. 25-2293

with a breathalyzer would be a “viable alternative.” Hobby Lobby, 573 U.S. at 728. 4 B. 18 U.S.C § 3553(a) Next, Broadfield argues the condition of his supervised re- lease completely banning his use of alcohol is a greater depri- vation of liberty than is necessary under § 3553(a), warranting modification. As discussed, any modification of the defendant’s original conditions of supervised release must, among other things, “involve no greater deprivation of liberty than is reasonably necessary for the purposes set forth in § 3553(a).” Evans, 727

4 We pause to note that we have previously recognized “significant ad- ministrative problems for the probation office” associated with ensuring compliance with a condition of supervised release can be considered in deciding whether the government has proffered the least restrictive means to advance its compelling interest. Israel, 317 F.3d at 772; see also United States v. Lafley, 656 F.3d 936, 942 (9th Cir. 2011) (“Requiring continuous monitoring of [defendant’s] marijuana use to determine whether the use was recreational or religious would place an unreasonable burden on a probation office.”). Still, the government bears the burden to come forth with sufficient evidence to permit the district court to make such a factual finding, specific to the particular defendant, in order to meet the prong’s demanding standard. Hobby Lobby, 573 U.S. at 728; Holt, 574 U.S. at 369 (noting that government’s “say-so” is not enough to show that its prof- fered means to advance its compelling interest is the least restrictive); Nunez v. Wolf, 117 F.4th 137, 151–52 (3d Cir. 2024) (noting that “imagina- tion” cannot stand in for evidence in the least restrictive means inquiry); Ware v. Louisiana Dep’t of Corr., 866 F.3d 263, 273–74 (5th Cir. 2017) (revers- ing the district court’s decision that the government had used the least restrictive means when “no evidence” supported the district court’s fac- tual finding); Ali v. Stephens, 822 F.3d 776, 793 (5th Cir. 2016) (same for government’s “conjecture”); McAllen Grace Brethren Church v. Salazar, 764 F.3d 465, 476 (5th Cir. 2014) (same). No. 25-2293 19

F.3d at 733 (quoting Ross, 475 F.3d at 873). District courts have “wide discretion” in this arena. Id. at 732 (citation omitted). On this score, Broadfield mostly puts forth the same argu- ments he made above to support his position. But, as we have already explained, the district court’s decision to deny Broad- field’s motion to modify in light of his particular history was more than reasonable. One argument relevant to this challenge remains. Broad- field insists that we find the district court abused its discretion because the court did not lay out his history of alcohol abuse and related criminality in its oral decision. But the district court judge couched its decision in Broadfield’s specific his- tory, explaining that “[h]istorically, [Broadfield] is dangerous when he drinks,” recalled that “[t]he last time he was in here … he admitted to drinking a bottle of liquor in 15 minutes,” and stated, in line with Broadfield’s attorney’s statement at the revocation hearing, that Broadfield “doesn’t deal with stress well.” Those comments, coupled with the fact that the district court adopted the violation report’s factual findings, which outlined Broadfield’s long criminal history, alcohol disorder, and struggles with substance abuse, demon- strate the district court adequately considered Broadfield’s specific history and characteristics when coming to its conclu- sion. See United States v. Erving, 164 F.4th 953, 965 (7th Cir. 2026) (noting we review a transcript “in context and as a whole”); Martin, 109 F.4th at 988 (explaining that appellate re- view of a revocation sentence is highly deferential); Boulting- house, 784 F.3d at 1178 (noting our review focuses on the sen- tencing court’s statements on the record to reflect that it con- sidered the appropriate factors). 20 No. 25-2293

III. CONCLUSION Prohibiting Broadfield from consuming alcohol is the least restrictive means to advance the government’s compelling in- terest under RFRA and does not involve a greater deprivation of liberty than necessary for the purposes set forth in § 3553(a). Thus, we AFFIRM.