Permissible Authorization of PSR and Medical Record Disclosure to Treatment Providers Under Supervised Release in US v. Harris

Introduction

United States v. Harris (2d Cir. Apr. 8, 2025) clarifies the scope of a district court’s authority to impose special conditions of supervised release, including the sharing of a defendant’s presentence report (PSR) and medical or psychological records with court‐approved treatment providers.

Defendant‐Appellant Aimee Harris pleaded guilty to one count of conspiracy to commit interstate transportation of stolen property in violation of 18 U.S.C. § 371. The district court imposed a below‐Guidelines sentence (one month imprisonment followed by three years of supervised release) and attached special conditions: outpatient mental health and substance abuse treatment, and a grant of authority to the probation officer to release Harris’s PSR and prior treatment records to her new providers. Harris appealed, arguing that (1) the court erred in authorizing disclosure of her confidential records without her consent, and (2) it improperly delegated decision-making about that disclosure to her probation officer. The Second Circuit affirmed.

Summary of the Judgment

The Second Circuit held, by summary order, that:

Review of special‐condition sentencing decisions is for abuse of discretion, but because Harris did not object below, the plain‐error standard applied;
The authorization to share Harris’s PSR and medical records with court-approved treatment providers is “self-evidently” reasonable because it advances her rehabilitation and public safety interests under 18 U.S.C. §§ 3553(a), 3583(d) and U.S.S.G. § 5D1.3(b)(1);
Harris’s privacy interests are diminished during supervised release, and her treatment providers remain bound by professional confidentiality obligations;
Delegation of “minor details” such as which records or portions to release does not impermissibly shift core sentencing authority from the court to the probation officer;
No clear or obvious error occurred, plain or otherwise, and the district court’s judgment is AFFIRMED.

Analysis

Precedents Cited

United States v. Kunz, 68 F.4th 748 (2d Cir. 2023): Clarifies that special conditions of supervised release are reviewed for abuse of discretion.
United States v. Dupes, 513 F.3d 338 (2d Cir. 2008): Upheld a probation officer’s access to mental health treatment records, holding that such a waiver “well may advance [the defendant’s] treatment” and public safety.
United States v. Betts, 886 F.3d 198 (2d Cir. 2018): Requires an individualized assessment and an on‐the‐record explanation for special conditions, though self‐evident reasoning in the record may suffice.
United States v. Matta, 777 F.3d 116 (2d Cir. 2015): Distinguishes between core sentencing authority (which cannot be delegated) and “minor details” (which may be).
United States v. Peterson, 248 F.3d 79 (2d Cir. 2001): Holds that delegation of the decision whether to impose a mental health condition is impermissible.
United States v. Oliveras, 96 F.4th 298 (2d Cir. 2024): Explains the diminished expectation of privacy of supervised‐release defendants.
United States v. Abrar, 58 F.3d 43 (2d Cir. 1995): Confirms that a condition need only be reasonably related to one of the § 3553(a) factors.

Legal Reasoning

The Second Circuit’s reasoning rests on several key principles:

Statutory and Guidelines Framework: Under 18 U.S.C. § 3583(d)(1) and U.S.S.G. § 5D1.3(b)(1), a district court may attach special conditions if they are “reasonably related” to the nature of the offense, the defendant’s history and characteristics, deterrence, public safety, or the defendant’s need for treatment.
Self-Evident Justification: Even though the district court did not explicitly state why record disclosures were necessary, the record makes plain that treatment providers need access to accurate background information (criminal conduct, substance use history, psychological assessments) in order to deliver meaningful therapy and reduce recidivism.
Diminished Privacy: A supervised‐release defendant has a reduced expectation of privacy. Disclosure to treatment providers—who are themselves professionally bound to confidentiality—does not violate any protected right.
Delegation of Minor Details: The court mandated the substance abuse and mental health conditions; it did not leave to the probation officer the decision whether Harris must attend treatment. The probation officer’s role is limited to determining which records or portions to release, analogous to selecting a provider or scheduling sessions. Matta confirms that such delegation is permissible.
Plain‐Error Review: Because Harris did not object at sentencing, she had to show an obvious legal error affecting her substantial rights and the fairness of proceedings. No such error exists given binding precedent (Dupes, Matta) and clear statutory authority.

Impact

US v. Harris offers practical guidance for district courts and defense counsel:

It reaffirms that courts may impose and enforce mandatory mental health and substance abuse treatment conditions—complete with access to prior records—without running afoul of privacy or delegation doctrines.
It underscores that treatment efficacy and public safety justify disclosure of a defendant’s full background to therapists and counselors.
It sets a clear boundary: courts must decide core sentencing issues, but may delegate administrative details to probation officers.
It signals that future challenges to similar disclosure conditions will face a high bar under plain‐error review absent an explicit workout of new law.

Complex Concepts Simplified

Special Conditions of Supervised Release: Extra requirements beyond imprisonment and probation—such as therapy, community service, or travel restrictions—that a court may impose to meet statutory goals (deterrence, rehabilitation, public protection).
Presentence Report (PSR): A confidential document prepared by probation officers summarizing a defendant’s criminal history, personal background, and sentencing recommendations.
Plain‐Error Review: An appellate standard applying when a party forfeits an objection at trial. The appellant must show the error was obvious, affected substantive rights, and undermined the trial’s integrity.
Delegation vs. Core Judicial Authority: Core sentencing decisions (e.g., whether to impose a condition or not) must be made by the judge. Minor choices (e.g., which records to release, which approved provider to use) may be assigned to probation officers.
Diminished Expectation of Privacy: Convicted persons under supervised release have fewer privacy protections; courts may limit their confidentiality rights when tied to legitimate supervisory needs.

Conclusion

United States v. Harris reaffirms a district court’s broad discretion to impose specialized conditions of supervised release that facilitate effective treatment and protect the public. By confirming that a court may authorize a probation officer to share a defendant’s PSR and medical or psychological records with approved treatment providers—and that delegating such record‐assignment decisions to probation does not exceed judicial authority—the Second Circuit has provided clear precedent. This decision bolsters the tools available to sentencing courts to tailor rehabilitative conditions, and it underscores the judiciary’s primacy in substantive sentencing choices, reserving administrative details for probation supervision.