DENVER, CO, October 16, 2025 — The U.S. Court of Appeals for the Tenth Circuit vacated the sentence of Jason Cory Bycroft, ruling that the district court plainly erred by imposing a lifetime ban on internet use without explaining its reasoning or conducting the required statutory analysis.
Bycroft was convicted in the Eastern District of Oklahoma on two counts of sexual exploitation of a child and two counts of possession of child pornography. His supervised release included a condition barring internet access without prior written approval from his probation officer.
Judge David M. Ebel, writing for the panel, found that the district court failed to analyze whether the condition met the requirements under 18 U.S.C. § 3583(d), which governs special conditions of supervised release. The court emphasized that such a restriction “is an extreme measure” requiring “extraordinarily careful review and adequately explained supporting findings.”
The appellate panel noted that the record did not show the internet was used to distribute or obtain child pornography, only to store material, and concluded there was no basis to treat the case as an “extreme” one warranting a total ban.
The case was remanded for resentencing so the district court can provide justification or modify the condition consistent with federal law.
