Self-Evident Rationale for PSR and Medical Record Disclosure to Treatment Providers in Supervised Release

Introduction

United States v. Harris is a summary order issued on April 8, 2025 by the United States Court of Appeals for the Second Circuit. The case arises from the conviction of Aimee Harris for conspiracy to commit interstate transportation of stolen property under 18 U.S.C. § 371. After pleading guilty, Harris received a downward‐variant sentence of one month’ imprisonment followed by three years of supervised release. As part of her supervision, the district 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 medical records with those treatment providers without separately obtaining her consent.

The primary issue on appeal was whether the district court (1) erred in authorizing the release of Harris’s PSR and medical/psychological evaluations to treatment providers without her express consent, and (2) impermissibly delegated to her probation officer the decision of which records should be shared. The Second Circuit affirmed, holding that the rationale for such disclosures is “self-evident,” and that allowing a probation officer to manage the limited record‐sharing details does not unlawfully delegate judicial authority.

Summary of the Judgment

The Second Circuit unanimously affirmed the district court’s sentence and special‐condition orders. Key findings include:

The district court acted within its broad discretion under 18 U.S.C. § 3583(d) and U.S.S.G. § 5D1.3(b)(1) in requiring Harris to undergo outpatient substance‐abuse and mental‐health treatment.
Although Harris did not object below, any challenge to the release‐of‐records conditions is reviewed for plain error—and none was found.
The justification for sharing Harris’s PSR and prior treatment records with the providers is “self-evident”: effective treatment requires access to pertinent background information.
Delegating to the probation officer the determination of which portions of the records need to be disclosed does not constitute an impermissible delegation of the court’s sentencing power.

Analysis

Precedents Cited

The court relied on multiple Second Circuit precedents to frame its analysis:

United States v. Betts, 886 F.3d 198 (2d Cir. 2018): District courts must make an individualized assessment of any special condition and state on the record the reason for imposing it, unless the rationale is otherwise “self-evident.”
United States v. Dupes, 513 F.3d 338 (2d Cir. 2008): A waiver of therapeutic confidentiality allowing a probation officer to access a defendant’s treatment records may be upheld where it reasonably furthers the defendant’s treatment and public safety.
United States v. Matta, 777 F.3d 116 (2d Cir. 2015): Courts may not delegate to probation officers decisions that effectively make a defendant’s liberty contingent on the probation officer’s discretion, but may delegate “minor details” such as the selection of a provider.
United States v. Peterson, 248 F.3d 79 (2d Cir. 2001): Delegation violates § 3583 when a probation officer’s future decision determines whether a mental‐health intervention must occur—but not when the court has already mandated treatment.

Legal Reasoning

The court’s reasoning proceeded in three steps:

Scope of Review. Because Harris did not object to the special‐condition language at sentencing, the court applied the plain‐error standard: error must be clear or obvious and affect substantial rights.
Rationale for Disclosure. Under U.S.S.G. § 5D1.3(b)(1)(D) and 18 U.S.C. § 3583(d)(1), special conditions must be “reasonably related” to providing medical or correctional treatment in the most effective manner and protecting the public. The court held that permitting a probation officer to share the PSR and pertinent medical records with court‐appointed therapists is “self-evident” because:
- An outpatient program is ineffectual if the provider lacks essential background on the defendant’s history, criminal conduct, or prior diagnoses.
- Restricting disclosure would frustrate the supervisory and rehabilitative goals of supervised release.
Delegation Doctrine. Citing Matta and Peterson, the court distinguished between delegating the decision to require treatment (impermissible) and delegating the selection or provision of records (permissible). Here, the court itself mandated treatment; it only authorized the probation officer to determine, “in the course of supervision,” which records are needed to implement that order.

Impact

United States v. Harris clarifies two important points in the law of supervised release:

Record-Sharing Is Permissible. District courts may authorize probation officers to share PSRs and medical or psychological evaluations with court‐ordered treatment providers when doing so is reasonably related to the defendant’s rehabilitation and public‐safety interests.
Limited Delegation Allowed. Imposing a mandatory treatment condition does not violate separation of powers when the only delegation is over ancillary details—such as identifying which portions of the record are pertinent to the treatment plan.

Future sentencing proceedings in the Second Circuit will now have a clear benchmark: when imposing mental‐health or substance‐abuse conditions, judges may rely on the “self-evident” rationale for record sharing, and probation officers may manage the logistical details without fear of reversal.

Complex Concepts Simplified

Presentence Investigation Report (PSR): A confidential document prepared by probation officers describing a defendant’s personal history, criminal record, and other relevant factors. Courts often use it to calculate sentencing ranges.

Special Conditions of Supervised Release: Beyond standard conditions (e.g., no new crimes), courts may impose tailored requirements—such as drug testing or therapy—if they are reasonably related to sentencing goals like rehabilitation and public safety.

Plain‐Error Review: When a defendant fails to object at trial or sentencing, an appellate court will only correct “plain” (clear and obvious) errors that seriously affect fairness, integrity, or the outcome of the case.

Delegation Doctrine: Sentencing courts retain exclusive authority to impose conditions of release, but they may delegate minor administrative details (e.g., scheduling or record-sharing logistics) to probation officers.

Conclusion

United States v. Harris reaffirms the broad discretionary authority of district courts under 18 U.S.C. § 3583(d) and U.S.S.G. § 5D1.3 to craft supervised‐release conditions that advance rehabilitation and public safety. By endorsing the “self-evident” need for treatment providers to access a defendant’s PSR and medical history—and by permitting probation officers to coordinate those disclosures—the Second Circuit has provided clear guidance for future sentencing. This decision strengthens the bridge between the federal courts and community‐based therapeutic programs and ensures that treatment plans are informed, focused, and capable of achieving their rehabilitative objectives.