United States v. Sayles, No. 13-1834 (8th Cir. 2014)
Annotate this CaseDefendants Martinus and Maurice appealed their sentences after pleading guilty to conspiracy to commit wire fraud. The court concluded that Martinus's eighty-five month sentence was substantively reasonable where the district court considered the appropriate factors in varying from the guidelines and adequately explained its sentence. Because the district court would have sentenced Maurice to the same sentence even without the government's breach of the plea agreement, the court could not say that the breach of the plea agreement required reversal under the plain error standard; the district court sufficiently explained the defendant-specific facts relevant to sentencing Maurice and the district court did not plainly err in sentencing Maurice to the same term of imprisonment as Martinus; and Maurice's sentence was substantively reasonable.
Court Description: Criminal case - Sentencing. Defendants' sentences were not substantively unreasonable where the district court varied upwards based on their criminal history, their roles in the offense, the seriousness of the offenses, and the need for deterrence and public protection; since defendant Maurice Sayles' sentence would have been the same without the government's comments at sentencing, this breach of the plea agreement did not require reversal under the plain error standard.
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