United States v. Rene Bravo

CourtCourt of Appeals for the Eleventh Circuit
DecidedMarch 20, 2026
Docket25-11502
StatusUnpublished

This text of United States v. Rene Bravo (United States v. Rene Bravo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Rene Bravo, (11th Cir. 2026).

Opinion

USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 1 of 6

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11502 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

RENE BRAVO, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 6:24-cr-00066-CEM-RMN-1 ____________________

Before ROSENBAUM, GRANT, and BLACK, Circuit Judges. PER CURIAM: Rene Bravo appeals the district court’s imposition of a stand- ard condition of supervised release that requires him to work full- USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 2 of 6

2 Opinion of the Court 25-11502

time and special conditions that require him to submit to poly- graph testing and have no direct contact with minors, as part of his sentence for attempted coercion and enticement of a minor to en- gage in sexual activity. Bravo contends the district court’s imposi- tion of these supervised release conditions rendered his sentence substantively unreasonable because the court did not explain why it imposed these arbitrary conditions. He asserts the full-time em- ployment condition was arbitrary because he receives retirement income and will be eligible for social security benefits upon his re- lease from prison, the polygraph condition is arbitrary because he did not commit a crime of dishonesty, and the prohibition of direct contact with all minors is arbitrary because his offense did not in- volve male minors. Section 5D1.3(c) of the Sentencing Guidelines lists standard conditions of supervised release, including as relevant: “[t]he de- fendant shall work full time (at least 30 hours per week) at a lawful type of employment, unless the probation officer excuses the de- fendant from doing so.” U.S.S.G. § 5D1.3(b)(2)(G). A district court may also order special conditions of supervised release so long as each condition: (1) is reasonably related to the nature and circum- stances of the offense, the history and characteristics of the defend- ant, the need for adequate deterrence, the need to protect the pub- lic, and the need to provide the defendant with needed training, medical care, or correctional treatment in an effective manner; (2) involves no greater deprivation of liberty than is reasonably nec- essary to accomplish the goals of deterrence, protecting the public, USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 3 of 6

25-11502 Opinion of the Court 3

and rehabilitation; and (3) is consistent with any pertinent Sentenc- ing Commission policy statements. 18 U.S.C. §§ 3583(d)(l)–(3), 3553(a)(1), (a)(2)(B)–(D); U.S.S.G. § 5D1.3(b)(1). It is not necessary for a special condition to be supported by each § 3553(a) factor, but rather, each factor is an independent consideration to be weighed. United States v. Tome, 611 F.3d 1371, 1376 (11th Cir. 2010). In United States v. Zinn, the defendant pleaded guilty to pos- session of child pornography and was sentenced to a term of in- carceration followed by supervised release, subject to the special condition that, “[he] shall have no direct contact with minors under the age of 18 without the written approval of the probation officer and shall refrain from entering into any area where children fre- quently congregate including schools, day care centers, theme parks, playgrounds, et cetera.” 321 F.3d 1084, 1086-87 (11th Cir. 2003). He challenged, for the first time on appeal, the no contact with minors special condition of supervised release, and we con- cluded the district court did not err and affirmed without further discussion. Id. at 1088. He also challenged the special condition that he submit to polygraph testing, which we affirmed on the basis that he had severe psychological problems, and this condition was reasonably related to his offense and personal history. Id. at 1089- 90. In United States v. Taylor, the defendant pleaded guilty to us- ing the internet “to transmit information about a minor with the intent to entice, encourage, offer, or solicit any person to engage in [criminal] sexual activity with the minor” and to possession of a USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 4 of 6

4 Opinion of the Court 25-11502

firearm by a convicted felon. 338 F.3d 1280, 1282 (11th Cir. 2003) (quotation marks omitted). As part of his sentence, the court im- posed a polygraph testing provision, which Taylor challenged. Id. at 1283. We rejected his challenge, determining the polygraph test- ing was reasonably related to his conviction, was not vague, and did not violate the Fifth Amendment privilege against self-incrimi- nation. Id. at 1283-83. The court also imposed the special condi- tion of supervised release that he have no direct contact with mi- nors without his probation officer’s written approval and that he “refrain from entering into any area where children frequently congregate, including schools, day care centers, theme parks, play- grounds, etc.” Id. at 1286. He challenged that condition, and, on appeal, we held the district court did not abuse its discretion in im- posing the condition, citing Zinn and two out-of-circuit cases. Id. (citing United States v. Paul, 274 F.3d 155, 157 (5th Cir. 2001); United States v. Gallo, 20 F.3d 7, 12 (1st Cir. 1994)). We also found there was no plain error in imposing a special condition prohibiting the defendant’s contact with minors because the defendant’s argument was foreclosed by our prior decisions in Zinn and Taylor and the special condition promoted rehabilitation and protected the public. United States v. Moran, 573 F.3d 1132, 1140 (11th Cir. 2009). We added “the district court was entitled to find that a restriction on [the defendant’s] affiliation with children was justified based on previous incidents involving minor victims.” Id. USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 5 of 6

25-11502 Opinion of the Court 5

As an initial matter, the standard of review for Bravo’s claim is plain error because he did not object to the district court’s impo- sition of his conditions of supervised release. 1 See Zinn, 321 F.3d at 1087 (stating where a defendant fails to “clearly” object to the con- ditions of supervised release in the district court, we review for plain error). Bravo has not shown plain error because he has not cited any authoritative precedent from the Supreme Court or this Court holding a district court errs by imposing conditions of super- vised release that require sex offenders to work full-time, submit to polygraph testing, and have no contact with minors. See United States v. Kushmaul, 984 F.3d 1359, 1363 (11th Cir. 2021) (stating with- out explicit, on-point language in the relevant statute, “there can be no plain error where there is no precedent from the Supreme Court or us directly resolving” the issue (quotation marks omit- ted)).

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Related

United States v. Larry James Ridgeway
319 F.3d 1313 (Eleventh Circuit, 2003)
United States v. Karl P. Zinn
321 F.3d 1084 (Eleventh Circuit, 2003)
United States v. Taylor
338 F.3d 1280 (Eleventh Circuit, 2003)
United States v. Moran
573 F.3d 1132 (Eleventh Circuit, 2009)
United States v. Tome
611 F.3d 1371 (Eleventh Circuit, 2010)
United States v. Gallo
20 F.3d 7 (First Circuit, 1994)
United States v. Ronald Scott Paul
274 F.3d 155 (Fifth Circuit, 2001)
United States v. Nakey Demetruis White
837 F.3d 1225 (Eleventh Circuit, 2016)
United States v. Jason Kushmaul
984 F.3d 1359 (Eleventh Circuit, 2021)

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Bluebook (online)
United States v. Rene Bravo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-rene-bravo-ca11-2026.