Authorizing Disclosure of PSR and Mental-Health Records to Treatment Providers: Limits on Delegation in Supervised Release Conditions

Introduction

This commentary analyzes the Second Circuit’s summary order in United States v. Harris (24-1099-cr), decided on April 8, 2025. In that case, the defendant-appellant, Aimee Harris, pleaded guilty to conspiracy to commit interstate transportation of stolen property under 18 U.S.C. § 371. At sentencing, the district court imposed one month of imprisonment (below the Guidelines range of 4 to 10 months) followed by three years of supervised release. As part of supervised release, the court required Harris to participate in outpatient substance-abuse and mental-health treatment and authorized her probation officer to share her presentence investigation report (PSR) and prior treatment records with those providers. On appeal, Harris contended that the court erred (1) by approving disclosure of her PSR and medical records without her consent and (2) by impermissibly delegating that disclosure decision to her probation officer. The Second Circuit affirmed, holding that these conditions are within the district court’s broad discretion and that the limited delegation of record-sharing details did not impermissibly cede judicial authority.

Summary of the Judgment

The Court of Appeals for the Second Circuit unanimously affirmed the district court’s judgment. Key points of the decision include:

• The district court’s authorization for the probation officer to release Harris’s PSR and treatment records to her substance-abuse and mental-health providers is “reasonably related” to the goals of supervised release under U.S.S.G. § 5D1.3(b)(1) and 18 U.S.C. §§ 3553(a), 3583(d).
• Because special conditions need only be reasonably related to one sentencing factor (such as rehabilitation), and an individualized assessment was evident, the condition survives abuse-of-discretion review.
• Harris’s privacy interest in her PSR and medical records is diminished during supervised release, and confidentiality obligations bind treatment providers.
• The court did not improperly delegate core sentencing decisions to the probation officer; it merely entrusted the officer with “minor details” (which records, or portions thereof, to share) in service of the mandatory treatment requirement.
• No plain error occurred, given binding Second Circuit precedent supporting similar record-sharing and limited delegation.

Analysis

1. Precedents Cited

• U.S.S.G. § 5D1.3(b)(1): Authorizes special conditions of supervised release that are “reasonably related” to sentencing factors, including medical care and correctional treatment.
• 18 U.S.C. §§ 3553(a), 3583(d): Statutory authority for supervised release conditions related to deterrence, public protection, and treatment of the defendant.
• United States v. Betts, 886 F.3d 198 (2d Cir. 2018): Requires an individualized assessment for special conditions and allows upholding a condition if the rationale is “self-evident” in the record.
• United States v. Dupes, 513 F.3d 338 (2d Cir. 2008): Approved a waiver of therapeutic confidentiality giving a probation officer access to a defendant’s mental-health records, finding it advanced treatment and public safety.
• United States v. Matta, 777 F.3d 116 (2d Cir. 2015): Differentiated between impermissible delegation of fundamental sentencing choices versus permissible delegation of minor details (e.g., selecting a provider or schedule).
• United States v. Peterson, 248 F.3d 79 (2d Cir. 2001): Held that requiring mental-health intervention only “if directed” by a probation officer is an impermissible delegation of judicial authority.
• United States v. Oliveras, 96 F.4th 298 (2d Cir. 2024): Confirmed that defendants under supervised release have a diminished privacy expectation in their records.

2. Legal Reasoning

The court’s analysis proceeded in three stages:

1. Scope of Discretion
   District courts have broad discretion to impose special conditions of supervised release so long as they are reasonably related to the offense, the defendant’s history and characteristics, and the goals of sentencing (18 U.S.C. § 3583(d); U.S.S.G. § 5D1.3(b)(1)).
2. Plain Error Review
   Because Harris did not object below, the court reviewed for plain error, asking whether any clear or obvious error affected her substantial rights and the fairness of proceedings. Citing Miller and Dupes, the panel concluded that no such error existed.
3. Delegation Analysis
   The court distinguished between delegation of core sentencing choices (forbidden) and delegation of minor logistical details (permissible). Here, the decision to require outpatient treatment was made at sentencing; only the identification of which records or portions thereof to share was left to the probation officer—a permissible delegation under Matta.

3. Impact on Future Cases

This decision reaffirms and clarifies three important principles:

• District courts may require mental-health and substance-abuse treatment as conditions of supervised release and may authorize sharing of PSRs and prior treatment records with providers when reasonably related to treatment goals.
• Defendants on supervised release possess a reduced privacy interest, and confidentiality obligations of healthcare professionals protect against broader disclosure.
• Courts retain exclusive authority over the fundamental decision to impose conditions but may delegate “minor details” (such as which records to disclose) to probation officers without offending separation of powers.

Lower courts will likely rely on this case to justify record-sharing authorizations and to structure delegation clauses narrowly to avoid claims of improper delegation.

Complex Concepts Simplified

• Special Conditions of Supervised Release: Extra terms (beyond imprisonment) imposed after release, aimed at rehabilitation and public safety (e.g., counseling, electronic monitoring).
• Presentence Investigation Report (PSR): A confidential report prepared by probation officers summarizing a defendant’s background, the offense, and sentencing recommendations.
• Plain Error Review: A method of appellate review applied when a party failed to object at trial, requiring the error to be obvious and to have impacted the outcome.
• Delegation of Judicial Authority: The principle that a judge cannot hand over core sentencing decisions (like whether to impose a condition) to probation officers, but may delegate procedural or logistical choices.
• Diminished Privacy Expectation: Convicted defendants under supervision have reduced privacy in certain records and activities, given ongoing oversight.

Conclusion

United States v. Harris cements the proposition that district courts have wide latitude to facilitate effective supervised-release treatment through disclosure of a defendant’s PSR and medical records to approved providers. At the same time, it delineates the boundary of acceptable delegation: courts may assign minor logistical tasks to probation officers—such as choosing which portions of records to release—without ceding their fundamental sentencing authority. This ruling balances defendant privacy interests with the practical needs of rehabilitation and public protection, providing a clear roadmap for future imposition of treatment-related conditions of supervised release.