CINCINNATI, OH – The U.S. Court of Appeals for the Sixth Circuit upheld a lower court’s decision requiring an Ohio man with a history of domestic violence to complete counseling before being allowed to live with any women.
The case involves Stephen Terrell Horn, who appealed a special condition of his supervised release that bars him from residing with women until he begins domestic violence treatment. Horn argued that the condition was overly broad and violated his right to association.
According to court records, Horn has multiple domestic violence convictions between 2012 and 2018, including assaults on his mother and a live-in girlfriend. While on state supervision, he was also convicted of firearm and drug-related offenses. After completing a 46-month federal prison sentence for possessing a firearm following domestic violence convictions, Horn violated several conditions of his supervised release within days of his release, including unauthorized drug use and living with the mother of his child without approval.
The district court reinstated supervision but imposed stricter conditions, citing Horn’s “deeply troubling” record of violence toward women. The Sixth Circuit found that the restriction was reasonably related to protecting others and preventing future harm, noting that it is temporary and may be lifted if Horn demonstrates progress in counseling.
Judge Jane B. Stranch wrote that the condition “bears a close nexus” to Horn’s criminal history and “is appropriately tailored” to the goals of rehabilitation and public safety.
The court affirmed the district court’s order in full.
