United States v. King — affirmed supervised-release condition clarifying who would supervise treatment

Case
United States of America v. Kristi Heather King
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
WILKINSON (Ronald Reagan, 1984); RICHARDSON (Donald Trump, 2018); Traxler (William J. Clinton, 1998)
Date Decided
July 29, 2026
Docket No.
25-4147
Topics
Supervised Release, Sentencing, Mental Health Treatment
Source
Read the full opinion

Background

Kristi Heather King pleaded guilty under a plea agreement to conspiracy to sex traffic a minor, in violation of 18 U.S.C. § 371. The district court sentenced her to 42 months in prison and two years of supervised release.

At sentencing, the district court orally required King to participate in a mental-health evaluation and treatment program, comply with the program’s rules, and take mental-health medications prescribed by a licensed healthcare practitioner. The written judgment also directed the probation officer to supervise the treatment in consultation with the treatment provider, including its location, modality, duration, and intensity. King appealed, arguing that this additional language created a material discrepancy between the oral sentence and written judgment.

The Court’s Holding

The Fourth Circuit affirmed in an unpublished per curiam opinion. It explained that a district court must orally pronounce all discretionary supervised-release conditions and that a material discrepancy between an oral sentence and written judgment can constitute reversible error. A discrepancy is material when the written judgment imposes a new condition or additional obligation, but written language may permissibly clarify an ambiguous oral pronouncement.

The court held that the written treatment-supervision language did not impose a new obligation on King that could not reasonably be expected to flow from the orally announced condition. Instead, it clarified who would supervise King’s treatment—an issue left ambiguous by the oral pronouncement. The discrepancy therefore was immaterial and did not require reversal.

Key Takeaways

  • Discretionary supervised-release conditions generally must be pronounced orally at sentencing.
  • A written judgment may clarify an ambiguity in an oral sentence without creating reversible error.
  • Authorizing probation to supervise the logistics of court-ordered mental-health treatment did not add a new obligation for King.

Why It Matters

The decision distinguishes a permissible clarification from a material alteration of a supervised-release condition. The key question is whether the written judgment adds a new obligation or merely supplies administrative details that reasonably flow from the condition announced in court.

For sentencing practitioners, the opinion underscores the importance of comparing the transcript and written judgment closely while recognizing that the two need not use identical language.

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