Fifth Circuit rejects supervised release residency condition

I am noticing more and more cases in which federal circuit courts are rejecting certain conditions of supervised release imposed by district courts.  I am wondering if this trend reflects district courts imposing more broad SR restrictions or circuit courts scrutinizing these restrictions more carefully.  Whatever explains the up-tick in these kinds of cases, a new Fifth Circuit decision in US v. Woods, No. 07-51491 (5th Cir. Oct. 28, 2008) (available here), reflects the trend  Here is the start of the Woods decision:

Defendant-appellant Briane Nicole Woods appeals the district court’s imposition of a discretionary condition of supervised release forbidding her from residing with any person to whom she is not ceremonially married or related by blood.  We conclude that the condition is overbroad and involves a greater deprivation of liberty than is reasonably necessary to achieve the purposes of supervised release.  Thus, the district court abused its discretion by imposing a supervised release condition that fails to meet a requirement set forth in 18 U.S.C. § 3583(d).  We vacate the condition of supervised release, affirm the remainder of the sentence, and remand.