The opinion builds on a trio of recent Eleventh Circuit cases:

1. United States v. Rodriguez, 75 F.4th 1231 (11th Cir. 2023) – Held that adding discretionary conditions in the written judgment, without oral pronouncement or explicit reference to a written list, violates the defendant’s Fifth Amendment right to be present at sentencing.
2. United States v. Hayden, 119 F.4th 832 (11th Cir. 2024) – Clarified that plain-error review applies when the district court does orally reference a specific written list (there, the Middle District of Florida’s form AO-245B), even if it does not read each condition aloud.
3. Olano, Shelton, and Perez – Standard formulations of the four-part plain-error test and situations where prejudice may be presumed.

The Kiggundu panel synthesized Rodriguez and Hayden: – If the court specifically identifies a single publicly available list, the notice requirement is satisfied (Hayden); – If it identifies none—or, as here, ambiguously gestures toward more than one— the notice requirement is violated (Rodriguez) and the conditions must be vacated.

The court’s reasoning unfolds in four steps:

1. Identification of Ambiguity. The sentencing judge’s phrase “standard conditions of supervision adopted by this court” could reference (a) Local Rule 32.1 (Southern District of Georgia) or (b) the national AO-245B defaults. Because the two lists diverge, the defendant lacked precise notice.
2. Due-Process Framework. The Fifth Amendment guarantees the defendant the right to be present when sentence is imposed (Rodriguez). Presence is meaningless without clarity: the conditions must be knowable at the hearing so counsel can object.
3. Error and Plainness. Under Shelton, an error is “plain” if it is contrary to “settled law.” Rodriguez and Hayden settled the rule that a court must either (i) read aloud each discretionary condition or (ii) adopt—clearly—an existing, publicly available list. The district court did neither; hence the error was plain.
4. Substantial Rights and Fourth Prong. Different obligations (e.g., reporting to probation within 72 hours vs. 48 hours, restrictions on firearms, etc.) demonstrate concrete prejudice: Kiggundu might have argued against some of the national conditions had he known they—not the local rule—were at issue. Vacatur, therefore, promotes “fairness, integrity, and public reputation” of judicial proceedings.

This decision tightens procedural requirements in the Eleventh Circuit:

• Sentencing Protocols. District judges must specify—on the record—the exact source of any “standard” conditions. A vague reference will trigger reversible error when conflicting lists exist.
• Local Rule Harmonization. Districts within the circuit may revisit local rules and standing orders to ensure consistency with AO-245B or make overlaps explicit. Redundant local lists may be rescinded to avoid confusion.
• Defense Advocacy. Defense counsel should affirmatively request clarification whenever multiple sets of standards could apply; failure to do so will not necessarily forfeit the issue if the written judgment diverges.
• Appellate Landscape. The opinion fills a gap between Rodriguez (no reference) and Hayden (clear reference), creating a middle category—ambiguous reference—subject to automatic vacatur.