Second Circuit: United States v. Washington

Consent to polygraph testing as a condition of supervised release is onerous and not invariably part of similar sentences; the addition of the requirement in the written sentence after omitting it in the spoken sentence was therefore an impermissible modification. 

http://www.ca2.uscourts.gov/decisions/isysquery/ebd08708-88fc-4318-b2eb-94e7493863f0/1/doc/17-2841_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/ebd08708-88fc-4318-b2eb-94e7493863f0/1/hilite/