The U.S. Court of Appeals for the Eighth Circuit has vacated a lifetime computer ban imposed on a Missouri man convicted of child pornography possession, ruling that the restriction was overly broad and must be reconsidered by the lower court.
In *United States v. Johnnie Lewis*, filed Feb. 6, 2026, the three-judge panel unanimously ruled that a special condition of supervised release preventing Lewis from possessing or using any computers violated federal sentencing guidelines. The decision marks another instance of federal appeals courts scrutinizing broad technology restrictions in child exploitation cases.
Lewis pled guilty to possessing child pornography as a prior offender in violation of 18 U.S.C. § 2252A(a)(5)(B). The U.S. District Court for the Eastern District of Missouri in St. Louis sentenced Lewis to a lifetime term of supervised release that included a complete prohibition on computer possession or use, as defined by the Computer Fraud and Abuse Act.
The case originated from Lewis's status as a repeat offender under federal child pornography statutes. Section 2252A(a)(5)(B) carries enhanced penalties for defendants with prior convictions involving the sexual exploitation of minors. While the court record does not detail Lewis's previous conviction, his classification as a prior offender subjected him to more severe sentencing guidelines.
The district court's lifetime computer ban referenced the definition of "computer" found in 18 U.S.C. § 1030(e)(1), which broadly encompasses any electronic device capable of processing information. This definition includes not only traditional computers but also smartphones, tablets, gaming systems, and many modern appliances with computing capabilities.
Writing for the Eighth Circuit panel, Circuit Judge L. Steven Grasz addressed a procedural dispute between the parties regarding the appropriate standard of review. The government apparently argued for abuse of discretion review, while Lewis's counsel likely sought plain error analysis. The court declined to resolve this disagreement, finding that even under the more stringent plain error standard, the computer ban must be vacated.
Under plain error review, appellate courts must find that the district court deviated from a legal rule, that the error was clear under current law, and that the error affected the defendant's substantial rights. The Eighth Circuit cited *United States v. Ristine* (8th Cir. 2003) in establishing this standard, indicating that all three elements were satisfied in Lewis's case.
The court's decision reflects growing judicial recognition that blanket technology restrictions in supervised release conditions may be constitutionally problematic. Federal law requires that supervised release conditions be reasonably related to the offense conduct, necessary for deterrence, and the least restrictive means of achieving legitimate penological goals.
Lifetime computer bans have faced increasing scrutiny from federal courts as technology becomes integral to modern life. Courts have noted that such restrictions can impede employment opportunities, medical care access, and basic social functioning. The restrictions become particularly problematic when they encompass devices beyond traditional computers.
The Eighth Circuit's brief opinion suggests the court found the lifetime ban either too broad in scope or unnecessarily restrictive given Lewis's circumstances. While the opinion fragment available does not detail the court's complete reasoning, the unanimous decision to vacate indicates clear legal error in the district court's approach.
The case returns to the Eastern District of Missouri, where the district judge must reconsider the computer restriction. On remand, the court will likely need to craft more narrowly tailored conditions that address legitimate supervision concerns while avoiding constitutional problems.
Possible alternatives might include restrictions on specific internet activities, required monitoring software, or prohibitions on accessing certain websites rather than a complete computer ban. The district court could also impose time limitations rather than lifetime restrictions.
The decision continues a trend of appellate courts requiring more precision in technology-related supervised release conditions. Similar cases have resulted in courts distinguishing between different types of devices or limiting restrictions to internet-capable equipment.
Lewis was represented on appeal by counsel whose arguments successfully persuaded the Eighth Circuit that the computer ban exceeded permissible bounds. The case was submitted to the court in November 2025 and decided within approximately three months.
The ruling affects supervised release practices throughout the Eighth Circuit, which includes Missouri, Arkansas, Iowa, Minnesota, Nebraska, North Dakota, and South Dakota. District courts in these jurisdictions must now ensure computer restrictions are carefully tailored to individual circumstances rather than imposing blanket prohibitions.
For Lewis, the victory means the possibility of supervised release conditions that allow some computer access under appropriate restrictions. The case will proceed on remand where the district court must balance public safety concerns with constitutional limitations on supervised release conditions.