U.S. Court of Appeals for the Eleventh Circuit, 2026

United States v. Rene Bravo

U.S. Court of Appeals for the Eleventh Circuit · Decided March 20, 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NOT FOR PUBLICATION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)). Bravo has not shown any case law that abrogates this Court’s precedent in Zinn or Taylor that upheld a sex offender’s polygraph condition, or any case law that abrogates this Court’s precedent in Zinn, Taylor, and Moran that upheld a sex offender’s condition of no contact with minors. See Zinn, 321 F.3d at 1088-90; Taylor, 338 F.3d at 1283, 1286; Moran, 573 F.3d at 1140; see also United States v. White,

1 Although Bravo frames his claim on appeal as one of substantive reasonable- ness, this Court has held that a defendant’s failure to object to his conditions of supervised release at his sentencing hearing subjects such claims to plain error review when raised for the first time on appeal. Zinn, 321 F.3d at 1087.

Bravo’s reiteration of his objection to his sentence’s length, which he raised prior to the court’s imposition of his conditions of supervised release, there- fore does not preserve his claims on appeal. See id. USCA11 Case: 25-11502 Document: 20-1 Date Filed: 03/20/2026 Page: 6 of 6

6 Opinion of the Court 25-11502 837 F.3d 1225, 1228 (11th Cir. 2016) (explaining we are bound to adhere to our prior panel precedent unless that precedent has been abrogated by this Court sitting en banc or by the Supreme Court).

Bravo argues his full-time employment condition of super- vised release is arbitrary because he receives retirement income and will be retirement age for social security purposes when re- leased from prison, but he does not contest that he had no assets and over $60,000 of liabilities. See United States v. Ridgeway, 319 F.3d 1313, 1317 (11th Cir. 2003) (stating when the condition im- posed is clear, and undisputed facts contained in the presentence investigation report support the condition, there is no error). He contends the full-time employment condition is also arbitrary be- cause no fine was imposed or restitution ordered, but disregards the fact the court waived his fine and special assessment because it found he was indigent—which he does not contest. While Bravo correctly asserts the district court did not specifically find his retire- ment benefits and social security benefits were insufficient to sus- tain him financially, such a finding is unnecessary because he has not contested the PSI’s assertion that he had no assets and $60,000 in liabilities, or the court’s finding that he was indigent. See id. Accordingly, the district court did not plainly err in imposing conditions of supervised release requiring Bravo to work full-time, submit to polygraph testing, and have no contact with minors.

AFFIRMED.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.