In the 

United States Court of Appeals 

For the Seventh Circuit ____________________

No. 16‐1492

UNITED STATES OF AMERICA,

Plaintiff‐Appellee,

v.

KRISTOPHER WARREN,

Defendant‐Appellant.

____________________

Appeal from the United States District Court for the

Western District of Wisconsin.

No. 15‐cr‐56‐wmc — William M. Conley, Chief Judge.

____________________

ARGUED SEPTEMBER 28, 2016 — DECIDED DECEMBER 5, 2016

____________________

Before POSNER, FLAUM, and MANION, Circuit Judges.

FLAUM, Circuit Judge. Kristopher Warren pled guilty to

transporting and possessing child pornography and was sen‐

tenced to five years’ imprisonment and fifteen years’ super‐

vised release. The district court entered an order modifying

Warren’s conditions of release pursuant to 18 U.S.C. § 3583(e).

Warren challenged three of the conditions, and the district

court dismissed his objections. We affirm.
2 No. 16‐1492

I. Background

Between September 18, 2003, and October 7, 2003, Warren

moderated a Yahoo! Group originally named “FunFotos4all.”

Warren founded this group, established its rules, and fre‐

quently changed the group’s name to evade enforcement of

Yahoo! Group rules. During this time period, Warren posted

to the group 117 images of child pornography, including im‐

ages titled “9yococksuck[1].jpg,” “12yoBondage.jpg,” and

“14yo girl‐bound and gagged.jpg”; images of prepubescent

and minor girls exposing their genital areas and being vagi‐

nally or orally penetrated by adult male penises; and at least

one image of a prepubescent girl being anally penetrated by a

minor boy. After images were posted to the group, Warren

sorted them into albums with titles such as “ForcedorTiedu‐

porCrying,” “hots Toys‐R‐US,” and “virgin.” He also posted

notices and comments to the group, including requests for

“new” images of child pornography that had not been previ‐

ously viewed on the Internet. The following are examples of

Warren’s comments:

• On September 19, 2003: “I have changed the name,

and made this a restricted group in hopes that it stays

open longer. Members are now required to send 2 pic‐

tures to obtain and keep membership.”

• On September 23, 2003: “I added a ton of pics and

regrouped them all so they’re easier to find. Please add

a photo or two to the ‘Add new pict here’ folder and I

will sort them. I think the group looks pretty good

right now but we could use some more pics. I’m re‐

jected [sic] any new members who haven’t added pics

and I’ll go through the members who are dead beats

later in the week. Post away!!!!”
No. 16‐1492 3

• On September 24, 2003: “Anyone interested in

young braless candid, or web cam hardcore? Please

post and I’ll start a folder.”  

• On September 28, 2003: “Added a ton, but need

some more help on pics – the photo albums are looking

good but we’re a little light in some areas. CANDID:

Nips showing through shirts, swimsuits, or bras, or

any personal ones, or stuff that hasn’t made the rounds

and is of the right age, lets [sic] add them to our collec‐

tion. FORCEDORTIEDORCRYING: Anyone have

some good young stuff. We don’t have many crying

pics yet. Any pics you want to add to the

ADDNEWPICS folder would be appreciated. GOOD

WORK EVERYONE, Your moderator.”

• On September 28, 2003: “I forgot one photo album

that is really weak, VIRGINS. People have been send‐

ing me a lot of requests so please send in your pics. An‐

ything with unbroken hymens, or popping a cherry for

the first time is good. Nothing will be rejected.”

• On September 30, 2003: “Real High school girls age

14‐17. No pictures that have made their way around

the internet. The pics must be very sexy and will be de‐

leted if they are not. Send a few to join.”

In February 2004, agents executed a search warrant at

Warren’s residence and seized his computer. A partial review

of the images on Warren’s computer revealed 263 images and

one video of child pornography, 135 images of child erotica,

297 images of subjects of an undetermined age engaging in

sexually explicit conduct, and 949 images of adult pornogra‐

phy. During his interview with the FBI, Warren admitted that
4 No. 16‐1492

he was part of the forum and that the child pornography on

the computer belonged to him.

From the time of his confession until 2009, Warren at‐

tended therapy, moved back to his hometown in Wisconsin,

and avoided further legal trouble. In March 2009, Warren was

charged with transportation of child pornography, in viola‐

tion of 18 U.S.C. § 2252(a)(2), and possession of child pornog‐

raphy, in violation of 18 U.S.C. § 2252(a)(4)(B), in the Central

District of California. Warren pled guilty in July 2009.1

In February 2010, Warren was sentenced to five years’ im‐

prisonment and fifteen years’ supervised release.2 Prior to

                                                  1 In his plea agreement, Warren agreed to particular conditions of su‐

pervised release if “imposed by the court.” The conditions included that

Warren would: (1) “participate in a psychological counseling and/or psy‐

chiatric treatment and/or sex offender treatment program, which may in‐

clude inpatient treatment, as approved and directed by the Probation Of‐

ficer. The defendant shall abide by all rules, requirements, and conditions of such

program, including submission to risk assessment evaluations and physiological

testing, such as polygraph and Abel testing;” and (2) “shall not associate or

have verbal, written, telephonic, or electronic communication with any

person under the age of 18, except: (a) in the presence of the parent or legal

guardian of said minor; and (b) on the condition that the defendant notify

said parent or legal guardian of his/her conviction in the instant of‐

fense/prior offense. This provision does not encompass persons under 18,

such as waiters, cashiers, ticket vendors, etc. with whom the defendant

must deal in order to obtain ordinary and usual commercial services.”

(emphasis added). The emphasized language from the first condition,

however, was omitted from the special condition in the actual Judgment

of Conviction, and the record does not explain this omission.

2 His conditions of supervised release included conditions that he

comply with the rules and regulations of the U.S. Probation Office and

General Order 318, which contains a condition stating that “the defendant
No. 16‐1492 5

sentencing, the government alleged that Warren’s computer

had also revealed his perusal of websites about drugging peo‐

ple, and photos of adult women, including his then‐girlfriend,

sleeping or otherwise unconscious and in various states of un‐

dress. Warren denied ever drugging or assaulting anyone, his

then‐girlfriend stated that the photos of her sleeping had been

taken consensually, and Warren was never charged with any

crime related to the pictures. The sentencing judge did not ad‐

dress the matter.  

During his five‐year prison term, Warren tutored inmates,

started a Sex Addicts Anonymous group, and became in‐

volved in “Life Connections,” a Christian residential‐reentry

preparation program. Warren also requested relocation of his

supervision to the Western District of Wisconsin. His request

was later approved, and at the end of his prison term, Warren

returned to Wisconsin. The Madison, Wisconsin probation of‐

fice petitioned the court to modify Warren’s conditions of su‐

pervised release to match the office’s standard language and

to add conditions that the office generally requests in “sex of‐

fender” cases. These conditions included, in relevant part, (1)

a travel condition, (2) a no‐contact‐with‐minors condition,

and (3) a polygraph condition. The judge appointed counsel

for Warren, and on June 22, 2015, Warren filed a brief object‐

ing to the proposed changes. During the hearing and media‐

tion process leading up to the district court’s final decision,

the parties stipulated with respect to the polygraph condition

that Warren’s treatment provider had not requested poly‐

graph testing; rather, the probation office would secure a pol‐

                                                 

shall not leave the judicial district without the written permission of the

court or probation officer.”
6 No. 16‐1492

ygraph examiner, in part for use in monitoring Warren’s com‐

pliance with supervision, and if probation thought the infor‐

mation provided during a polygraph exam might be relevant

to treatment, they would pass that information along.

On February 23, 2016, after briefing by the parties and a

hearing, the court issued an opinion and order on the defend‐

ant’s conditions of supervised release, which included the fol‐

lowing conditions:

Standard Condition No. 1: Defendant shall not

leave the judicial district in which defendant is

being supervised without the permission of the

court or probation officer.

Special Condition No. 4: Not associate with any

person under the age of 18 or have verbal, writ‐

ten, telephonic, or electronic communication

with any such person, except with the express

permission of the minor’s parent or legal guard‐

ian and the supervising U.S. probation officer.

This provision does not include persons under

the age of 18, such as waiters, cashiers, ticket

vendors, etc., with whom defendant must deal

in order to obtain ordinary and usual commer‐

cial services.

Special Condition No. 7: Undergo a psychosex‐

ual evaluation, which may involve use of poly‐

graph examinations, as approved by the super‐

vising U.S. probation officer. Defendant shall

participate in an outpatient sex offender coun‐

seling program if recommended by the evalua‐
No. 16‐1492 7

tor, which may involve the continued use of pol‐

ygraph examinations, as approved by the su‐

pervising U.S. probation officer. Defendant’s an‐

swers to questions by the treatment provider,

probation officer and polygraph examiner shall

be truthful in all respects unless a fully truthful

statement would tend to incriminate defendant,

in violation of defendant’s constitutional rights,

in which case defendant has the right to remain

silent. Defendant shall follow all restrictions

and treatment requirements of the program.

Warren challenges these three conditions on ap‐

peal.

II. Discussion

With respect to claims of substantive error, we review con‐

tested conditions of supervised release for abuse of discretion.

United States v. Kappes, 782 F.3d 828, 844 (7th Cir. 2015); United

States v. Poulin, 809 F.3d 924, 930 (7th Cir. 2016), rehʹg denied

(Feb. 22, 2016). We review claims of procedural error de novo.

Poulin, 809 F.3d at 930. Throughout, “we must be mindful of

the fact that ‘[t]he sentencing judge is in a superior position to

find facts and judge their import under § 3553(a) in the indi‐

vidual case,’ and ‘district courts have an institutional ad‐

vantage over appellate courts in making these sorts of deter‐

minations, especially as they see so many more Guidelines

cases than appellate courts do.’” Kappes, 782 F.3d at 844 (quot‐

ing Gall v. United States, 552 U.S. 38, 51–52 (2007) (alteration in

original).

The Sentencing Reform Act of 1984 imposes a handful of

mandatory conditions and allows for additional discretionary
8 No. 16‐1492

conditions. 18 U.S.C. § 3583; United States v. Siegel, 753 F.3d

705, 707 (7th Cir. 2014). Certain discretionary conditions are

designated as “standard,” U.S.S.G. § 5D1.3(c), while others

are called “special,” id. §§ 5D1.3(d)‐(e), and are recommended

for particular offenses. Siegel, 753 F.3d at 707. Regardless, “all

discretionary conditions of supervised release must ... com‐

ply with overall federal sentencing policy as stated in 18

U.S.C. § 3553(a).” Id. These policy considerations include “the

nature and circumstances of the offense and the history and

characteristics of the defendant,” “the need for the sentence

imposed,” and “the kinds of sentences available.” United

States v. Thompson, 777 F.3d 368, 373 (7th Cir. 2015) (citing 18

U.S.C. § 3553(a)). Ultimately, a sentencing judge should con‐

sider four general principles when imposing conditions of su‐

pervised release:

(1) [T]he importance of advance notice of condi‐

tions being considered; (2) the need to justify the

conditions and the length of the term at sentenc‐

ing by an adequate statement of reasons, rea‐

sonably related to the applicable § 3553(a) fac‐

tors; (3) the goal of imposing only specific, ap‐

propriately‐tailored conditions—which is to

say, avoiding the imposition of vague or over‐

broad conditions; and (4) the requirement to

orally pronounce all conditions, with the writ‐

ten judgment only clarifying the oral pro‐

nouncement in a manner that is not inconsistent

with an unambiguous oral provision.

Kappes, 782 F.3d at 838–39. In essence, the imposed conditions

“cannot involve a greater deprivation of liberty than is rea‐
No. 16‐1492 9

sonably necessary to achieve the goals of deterrence, incapac‐

itation, and rehabilitation.” United States v. Goodwin, 717 F.3d

511, 522 (7th Cir.) (citing United States v. Holm, 326 F.3d 872,

876 (7th Cir. 2003)), cert. denied, — U.S. —, 134 S. Ct. 334 (2013).

A. Standard Condition No. 1: Travel Condition

Warren contends that the district court both procedurally

and substantively erred in imposing the travel condition

without adequate justification relating to his background,

crime, protecting the public, or any other goals of sentencing.

This condition, however, is an administrative requirement

that can be imposed without explanation. See Thompson, 777

F.3d at 378; see also Poulin, 809 F.3d at 931; Kappes, 782 F.3d at

848 (requiring non‐administrative conditions to be adequately

supported and not vague or overbroad). Warren counters

that, because he objected to the travel condition before the dis‐

trict court, this case is distinguishable from Kappes and Thomp‐

son. However, we never tied our holdings in those cases to the

fact that defendants did not initially challenge the travel con‐

dition.

Moreover, though it was not required to do so, the district

court articulated several sound reasons for the travel condi‐

tion, including that “it is related to tracking and controlling

defendant, given the nature of his offenses of conviction for

child sex offenses”; “[he] is a relatively wealthy businessman,

capable of traveling out of the judicial district without notice”;

it “serves as a general and specific deterrent”; “it serves to

protect the public”; and it allows probation officers to “more

easily accomplish[]” their “statutory duty to keep informed of

a defendant’s location, conduct, condition and compliance ...

within a district in which the officer is familiar and has un‐

questioned jurisdiction.” United States v. Warren, No. 15‐cr‐56‐
10 No. 16‐1492

wmc, 2016 WL 738779, at *7 (W.D. Wis. Feb. 23, 2016). Warren

argues that his offense did not include a travel‐related com‐

ponent; however, the fact that Warren committed his offense

from inside his home does not neutralize the potential threat

he poses to children outside his home. See Poulin, 809 F.3d at

927, 931–32 (concluding that a travel condition was justified

where defendant stored and viewed child pornography in his

basement); Kappes, 782 F.3d at 839, 849–50 (upholding travel

condition imposed on defendant who distributed and pos‐

sessed child pornography using a computerin his apartment).

Warren also argues that the travel condition is vague be‐

cause it is unclear what might be a basis for probation’s ap‐

proval or disapproval of any particular travel plans. But, as

we observed in Kappes, “[i]t is inherent in this system that con‐

ditions allow probation officers a degree of discretion in per‐

forming their difficult job.... [A]t some point, we must ‘fairly

presume [the defendant]’s probation officer will apply the

conditions in a reasonable manner.’” 782 F.3d at 857–58 (last

alteration in original) (citation omitted). This is certainly the

case with administrative conditions, such as this one, which

we have characterized as “necessary incidents of supervi‐

sion.” Id. at 843.

B. Standard Condition No. 4: No‐Contact‐With‐Minors

Condition

Warren next argues that the district court procedurally

and substantively erred in imposing the no‐contact‐with‐mi‐

nors condition.  

Procedurally, he claims the court erred when it mistakenly

referenced in its order imposing the no‐contact condition a

“previous violation while on supervised release.” Warren has
No. 16‐1492 11

not committed any such previous violation. This error is

harmless, however, as the other factors the court relied on to

justify the condition are sufficient to support its imposition.

These include defendant’s efforts to solicit new, specific kinds

of child pornography; the risk that he would promote the cre‐

ation of new child pornography; his perusal of websites

providing instructions on how to drug women; and his im‐

ages of apparently asleep or unconscious women with ex‐

posed breasts and genitals. Warren, 2016 WL 738779, at *10.

Further, the district court did not mention any previous su‐

pervised‐release violation in its opinion. See id. Thus, it is ap‐

parent this factor played little to no role in the court’s imposi‐

tion of this condition, and the error is harmless.  

Substantively, Warren contends the no‐contact provision

is inappropriate because it is not justified by the facts of his

case. Warren compares the case at hand to three cases where

we considered similar no‐contact provisions and concluded

they were overbroad: Thompson (where the defendant had an

online relationship with a teenage girl involving the exchange

of nude pictures, and later sexual intercourse), Kappes (where

the defendant downloaded child pornography, had been tak‐

ing photos of an underage girl at a nearby pool for the past

ten years, and had stolen and kept children’s underwear for

twenty years), and Jurgens3 (where the defendant possessed

child pornography of seven‐ and eight‐year‐olds, had been di‐

agnosed with pedophilia, and had stated that he “can’t do an‐

ything [to children] when they are not here”). Warren further

emphasizes that we characterized Jurgens’s offense as “per‐

haps the minimum of what might be sufficient to justify a no‐

                                                  3 This defendant’s appeal was consolidated and considered in Kappes,

782 F.3d at 839.
12 No. 16‐1492

contact provision in a possession‐only child‐pornography

case,” Kappes, 782 F.3d at 860. Warren argues that his own of‐

fense is less serious than all of these cases because he did not

commit a “hands‐on” offense with a minor, his criminal con‐

duct lasted for only nineteen days, and it occurred over

twelve years ago.  

Our case law clearly establishes that commission of a

“hands‐on” offense is not necessary to impose a no‐contact

condition. See, e.g., Kappes, 782 F.3d at 859; Poulin, 809 F.3d at

935 (holding that the district court did not abuse its discretion

in imposing a no‐contact condition on a possession‐only

child‐pornography offender where the court considered the

condition’s impact on the defendant’s familial relations, the

lack of a pedophilia diagnosis, and the lack of evidence that

he had acted out sexually toward a child). Where a posses‐

sion‐based offense is sufficiently serious, a tailored no‐contact

provision may be imposed. See, e.g., Kappes, 782 F.3d at 859.  

On appeal, Warren downplays his criminal conduct. He

argues that “most of [his forum] was lawful pornography,”

that “there’s no evidence that Warren ever had a specific in‐

terest in children (as opposed to pornography generally),”

and that his activity was “far removed from real children.” As

the government notes, however, “there is no indication in the

PSR [Pre‐Sentence Report] (or any other document) that the

Yahoo! Group that the defendant created and managed con‐

tained any adult pornography.” More importantly, possession

of adult pornography does not serve as the basis for his con‐

viction and sentence. Rather, Warren’s conviction centered on

the child pornography he admits he posted and encouraged

others to post in the forum. The file names, the content of the
No. 16‐1492 13

images he posted, and the comments he made all evince a spe‐

cific interest in children. He also actively and specifically so‐

licited new child pornography, creating a risk that real chil‐

dren would be further victimized. See United States v. Goldberg,

491 F.3d 668, 672 (7th Cir. 2007) (“Young children were raped

in order to enable the production of the pornography that the

defendant both downloaded and uploaded—both consumed

himself and disseminated to others. The greater the customer

demand for child pornography, the more that will be pro‐

duced.”). As such, the district court did not err in implicitly

finding Warren’s child‐specific interests and actions were at

least as serious as the “minimum” identified in Kappes, war‐

ranting the no‐contact condition.

Warren next takes issue with the district court’s statement

that it was not “willing to discount the possibility that the de‐

fendant’s past perusal of ‘instructional’ websites about drug‐

ging women, coupled with images found on the defendant’s

camera of apparently asleep or unconscious women with

breasts and genitals exposed, suggests related risks.” Warren,

2016 WL 738779, at *10. He argues that no court has ever made

findings of fact with respect to these allegations, and that they

are unrelated to the no‐contact condition, which focuses on

minors. Warren does not, however, dispute the fact that he

perused these websites and possessed these images. Moreo‐

ver, the district court, within its discretion, referred to the sug‐

gested risks raised by these facts only as they relate to minors.

See Kappes, 782 F.3d at 844. Indeed, although these particular

images were not of children, Warren’s apparent sexual inter‐

est in incapacitated and vulnerable women, considered to‐

gether with his specific solicitations of new child pornogra‐

phy, raise reasonable concerns regarding his contact with mi‐

nors. Finally, even without consideration of these facts, the
14 No. 16‐1492

district court’s other justifications for imposing the no‐contact

condition, as described in more detail above, are sufficient. See

Warren, 2016 WL 738779, at *10.

Finally, Warren argues that the no‐contact condition is

overbroad, as it could effectively bar him from participating

in any number of everyday activities (such as attending

church, sporting events, barbecues, or block parties) in which

minors, too, are often included. We uphold these types of con‐

ditions, however, when the district court reasonably con‐

cludes that the facts of the case justify them. See Poulin, 809

F.3d at 935. Additionally, the no‐contact condition here is

more narrowly tailored than those Warren points to. In

Thompson, we vacated a no‐contact condition, in part because

it did not exempt incidental contact with, for example, wait‐

resses or cashiers who could be minors. Id. at 376. The no‐con‐

tact condition here, however, does just that. Lastly, as the dis‐

trict court noted, imposing such an appropriately tailored

condition and allowing the probation office discretion to ap‐

prove or disapprove Warren’s attendance at various events or

locations where minors may be present is reasonable. See

Kappes, 782 F.3d at 859. Accordingly, the no‐contact condition

is not overbroad.

C. Standard Condition No. 7: Polygraph Condition

Finally, Warren contends the polygraph‐testing condition

imposes an inappropriate “probation‐monitoring‐focused

polygraph condition.” Relying on Siegel, Warren stresses that

we have previously taken issue with a condition requiring the

defendant to submit to polygraph testing, which may be part

of a sex offender treatment program as directed by the proba‐

tion office. 753 F.3d at 713 (alteration in original). There, we

questioned, “If physiological testing may be rather than must
No. 16‐1492 15

be part of the required sex‐offender treatment program, im‐

plying that it is not a mandatory part, why is it a free‐standing

requirement, imposed whether or not it is part of a sex‐of‐

fender treatment program? What other function could it

serve? Is it just a euphemism for giving the prisoner lie‐detec‐

tor tests?” Id. Warren concludes that polygraph tests are ap‐

propriate only when they are requested by the treatment pro‐

vider, and directed by and toward treatment, not monitoring.

The district court, however, relied on United States v. Brew‐

ster, 627 F. App’x 567 (7th Cir. 2015). There, we held that the

district court did not err in imposing a polygraph condition

unrelated to treatment, “as a means to insure compliance with

program requirements and restrictions,” given the defend‐

ant’s horrific conduct (sexually abusing his two daughters)

and his subsequent portrayal of himself to the district court as

a “good father.” We also noted that his lack of “honest self‐

assessment” made polygraph testing especially appropriate.  

Together, Siegel and Brewster demonstrate that determin‐

ing whether a polygraph condition is appropriate (e.g., with

respect to the extent to which it ought to be (1) tied to treat‐

ment and (2) under the purview of the treatment provider

versus the probation office) depends on the facts of each case.

Our holdings in Kappes and United States v. Rhodes, 552 F.3d

624 (7th Cir. 2009), further illustrate this principle. In Kappes,

we dismissed one defendant’s exception to a condition that he

“submit to physiological testing, including polygraph testing,

which may be part of a sex offender treatment program as di‐

rected by the U.S. Probation office”; because “we read this

condition as [simply] delegating to probation the selection of

the treatment provider.” 782 F.3d at 856. We noted that “only

the treatment provider is authorized to select the type(s) and
16 No. 16‐1492

amount of testing.” Id. In Rhodes, the condition at issue simi‐

larly stated that the defendant was to “undergo a psychosex‐

ual evaluation and participate in an outpatient sex offender

counseling program if recommended by the evaluator which

may involve use of polygraph and plethysmograph examina‐

tions.” 552 F.3d at 626. We observed, however, that “[p]erhaps

the counselor and the Probation Officer responsible for this

case may determine that [PPG] testing would not be efficient,

effective, economical, or necessary, or perhaps they would be

satisfied with polygraph testing alone, which is not unusual.”

Id. at 628. In sum, some cases may warrant the probation of‐

ficer’s involvement in polygraph examinations, while others

may not. This case‐by‐case approach preserves the sentencing

judge’s flexibility to consider the relevant circumstances and

craft an appropriately tailored condition.

Here, after considering all of the evidence, the district

court concluded the polygraph condition was necessary. The

court found that Warren’s “past criminal conduct ... acting as

a moderatorfor a private website group that actively solicited,

organized and posted new, disturbing images and videos of

child abuse ... is more than sufficient to defer to the Probation

Office’s recommendation that the defendant be subject to pol‐

ygraph testing ... at least for an initial period of his supervi‐

sion.” Warren, 2016 WL 738779, at *1. The court explained that

the polygraph testing was appropriate whether it was used

“to obtain a more complete sexual history, help the defendant

to confront the full context of his crime of conviction or to

monitor his ongoing compliance with treatment and super‐

vised release conditions.” Id. at *13. The court further noted

that “there is more than enough in this record to suggest that

defendant has yet to disclose the full scope of his past sexual

misconduct, is in denial about the full scope of his criminal
No. 16‐1492 17

conduct here and has given his Probation Officer pause about

his ongoing conduct.” Id. Indeed, Warren’s denial of the seri‐

ousness of his criminal conduct is further underscored by his

submissions on appeal that “there’s no evidence that [he] ever

had a specific interest in children” and that his conduct was

“far removed” from children. Ultimately, the district court

concluded that the polygraph condition—including its reli‐

ance on the probation officer’s discretion—was reasonable.

We agree. Accordingly, the district court did not abuse its dis‐

cretion in imposing it.

Warren also argues that in conjunction with its intrusive‐

ness, polygraph testing’s inaccuracy and unreliability out‐

weigh its usefulness in the context of supervised release. The

district court pointed to the efficacy of polygraph tests at pro‐

moting public safety, noting that they often reveal additional,

previously unknown behaviors that were either violations of

conditions of release or other “high‐risk” behavior. Warren,

2016 WL 738779, at *12. Regardless, as the district court ob‐

served, polygraph conditions have been upheld by every cir‐

cuit where the circumstances warranted it. See Warren, 2016

WL 738779, at *11 n.8 (collecting cases). We see no reason to

depart from that trend today.

III. Conclusion

For the foregoing reasons, we AFFIRM the judgment of the

district court.