CINCINNATI, OH — The U.S. Court of Appeals for the Sixth Circuit has upheld a lower court’s ruling that requires an Ohio man with a history of domestic violence to complete counseling before he is allowed to live with any women.
The case centers on Stephen Terrell Horn, who challenged a special condition of his supervised release that prevents him from residing with women until he begins domestic violence treatment. Horn claimed the condition was too broad and violated his right to association.
Court documents show that Horn has multiple domestic violence convictions between 2012 and 2018, including assaults on his mother and a live-in girlfriend. While under state supervision, he was also convicted of firearm and drug offenses.
After serving a 46-month federal prison sentence for possessing a firearm following domestic violence convictions, Horn violated several release conditions within days of getting out — including unauthorized drug use and living with the mother of his child without approval.
The district court responded by reinstating supervision with stricter conditions, citing Horn’s “deeply troubling” pattern of violence toward women.
The Sixth Circuit ruled that the restriction was reasonably related to protecting others and preventing future harm, emphasizing that it is temporary and can be lifted if Horn makes 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 meet the goals of rehabilitation and public safety.
The appellate court affirmed the district court’s order in full.
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