Kyle E. McClamma v. United States

This case was brought by Petitioner under Section 2255 for relief from a lifetime supervised release condition that restricts contact with one of his biological daughters. The Eleventh Circuit has declined to consider the merits of Petitioner's Section 2255 by invoking the "invited error" doctrine. The Eleventh Circuit's decision comes in light of holdings by the vast majority of circuit courts that 18 U.S.C. § 3583(d) requires district courts to provide a record of sufficient, reasonably related evidence to support a condition that restricts the parent/child relationship; and that such a condition may not be included in the written order without providing notice to the defendant at sentencing. Did the Eleventh Circuit err in holding that Petitioner's legal challenges to a previously imposed special supervised release condition restricting contact with his child are waived by the doctrine of "invited error" because Petitioner acquiesced to the additional demands of the Government to modify the scope of the condition over four years later? Did the district court violate Petitioner's right of Due Process when it failed to announce or explain the imposition of a special supervised release condition intended to restrict the parent/child relationship, and instead, later added the condition in a written order?