## Facts

- An undercover FBI agent entered an online chat room associated with trading child pornography and communicated with Arthur William Heckman.
- Heckman emailed the agent multiple sexually explicit images of minors after discussing trading child pornography.
- AOL identified the account used in the exchanges as Heckman’s; he was arrested and admitted receiving and transmitting 18 child-pornography images.
- Heckman had a long history of child-pornography distribution and continued similar conduct after prior incarceration and treatment.
- Heckman pleaded guilty to transporting child pornography under 18 U.S.C. § 2252(a)(1).
- The district court sentenced Heckman to 180 months’ imprisonment and lifetime supervised release with special conditions including: (1) a lifetime unconditional internet ban, (2) lifetime mental health program participation, and (3) a lifetime restriction on any interaction with minors.

## Issues

1. Whether a lifetime, unconditional ban on all internet access as a supervised-release condition satisfies 18 U.S.C. § 3583(d), including the requirement of no greater deprivation of liberty than reasonably necessary.
2. Whether a lifetime requirement to participate in a mental health program is reasonably related to sentencing goals and properly tailored under § 3583(d).
3. Whether a lifetime blanket restriction on any interaction with minors is sufficiently supported and narrowly drawn under § 3583(d).

## Decision

- Affirmed the mental health treatment condition.
- Vacated the lifetime unconditional internet ban as overbroad and inadequately justified.
- Vacated the blanket restriction on any interaction with minors as overly broad and insufficiently tailored.
- Remanded for resentencing to craft narrower, supported conditions consistent with § 3583(d).

## Legal Principles

- Special conditions of supervised release must be reasonably related to § 3553(a)(1) and (a)(2)(B)–(D), impose no greater deprivation of liberty than reasonably necessary, and be consistent with Sentencing Commission policy statements.  
- Conditions must be individually tailored to the defendant and offense and supported by record-based findings and a reasoned explanation.
- Because internet access is central to ordinary life, a lifetime categorical ban on all internet use is an extraordinary restraint and generally requires strong, specific justification and consideration of less restrictive alternatives (e.g., monitoring, limited prohibitions, or probation-officer approval).
- Broad bans on contact with minors must account for context and avoid unnecessarily restricting innocent, incidental, or family contact; limits should focus on the risk presented (e.g., unsupervised contact) and include workable safeguards.
- A mental health treatment condition may be upheld when tied to rehabilitation and public protection, particularly where the defendant’s history indicates ongoing risk, and when the condition allows professional and probationary discretion regarding treatment details.

## Conclusion

The Third Circuit held that supervised-release conditions in child-pornography cases may restrict internet use and contact with minors, but lifetime categorical prohibitions require individualized tailoring and adequate on-the-record justification; it therefore vacated Heckman’s lifetime internet and minor-contact bans while affirming mandated mental health treatment and remanding for narrower conditions.


United States v. Heckman, 592 F.3d 400 (3d Cir. 2010)