US v. Begay, -- F.3d --, 2011 WL 359355 (10th Cir. 2011) (NM) - The COA upholds the post-release modification of Mr. Begay's supervised release conditions to include polygraph testing. Mr. Begay was a convicted sex offender who was released to a halfway house after serving a 196-month sentence. Although he had not violated any of his conditions and there were no changed circumstances, the COA holds the district court had authority to grant the USPO request to add a polygraph testing condition. The COA pronounced itself "somewhat skeptical of the usefulness of polygraph testing as a supervision tool," and noted "significant reliability problems with polygraph testing," but concluded the district court had not abused its discretion by ordering it.