United States v. Ceasar, No. 19-2881 (2d Cir. 2021)
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Defendant pleaded guilty to one count of conspiracy to provide material support to a foreign terrorist organization—the Islamic State of Iraq and Syria (ISIS) (also referred to as the Islamic Sate of Iraq and the Levant or ISIL)—in violation of 18 U.S.C. 2339B(a). Defendant violated conditions of her presentence release by resuming contact with known supporters of ISIS and other extremist groups, attempting to conceal these communications from law enforcement authorities, and then lying to the FBI about her conduct. Defendant also pleaded guilty to obstruction of justice.
The Second Circuit vacated defendant's 48 month sentence, concluding that defendant's far-below-Guidelines range is substantively unreasonable. In this case, defendant faced a total Sentencing Guidelines range of 360 to 600 months' imprisonment, and her far-below-Guidelines sentence was outside the bounds of what was reasonable in light of the facts and circumstances of this case. The court explained that the district court assigned defendant's need for rehabilitation from years of trauma and abuse overwhelming weight while failing to give adequate consideration to the competing goals of sentencing—including the need for the sentence to protect the public, deter criminal conduct of the defendant specifically and others generally, promote respect for the law, and reflect the seriousness of the offense committed. Therefore, the district court abused its discretion and the court remanded for resentencing consistent with the 18 U.S.C. 3553(a) factors.
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