Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. EMILY SAHARA LAU

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-17 Docket: 1:18-cr-20326-DSL-1 The eleventh-circuit affirmed the district court’s imposition of a special condition of supervised release prohibiting the defendant, Emily Sahara Lau, from having contact with animals inside her home or place of residence. The court reviewed the procedural challenge regarding the district court’s explanation of the condition under the plain error standard, finding no error because the record provided a reasoned basis for the ruling that allowed for meaningful appellate review. Substantively, the court applied an abuse of discretion standard to evaluate whether the condition was reasonably related to the factors in 18 U.S.C. § 3553(a) and involved no greater deprivation of liberty than necessary under 18 U.S.C. § 3583(d). The court held that the condition was justified by Lau’s history of possessing sexually explicit materials depicting bestiality, noting that the restriction did not violate constitutional rights as it only limited contact within her residence while allowing interaction elsewhere, and that no Sentencing Commission policy statement rendered the condition invalid. As a practical consequence, the judgment and sentence are affirmed, though the court noted that Lau retains the right to seek future modification or termination of the condition under 18 U.S.C. § 3583(e)(2) should she demonstrate progress in her rehabilitation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.