United States v. Clayton, No. 15-1479 (8th Cir. 2016)
Annotate this CaseDefendant appealed his 279-month sentence after pleading guilty to bank robbery, brandishing a firearm in furtherance of a bank robbery, and being a felon in possession. The court concluded that the district court adequately explained the 18 U.S.C. 3553(a) sentencing factors, and the district court's earlier-recounted statements about why it was imposing less than the high-end sentence that it had intended to impose adequately explained why it believed that a low-end sentence would be inadequate in light of defendant’s criminal history and his behavior during the bank robbery. Accordingly, the court held that the district court did not commit procedural error, plain or otherwise, in sentencing defendant. The court also concluded that defendant's sentence was substantively reasonable where, in light of defendant's conduct during the bank robbery and his criminal history, the district court’s decision to sentence him to fifteen months longer than the statutory minimum does not represent a clear error of judgment. Finally, the cases cited by defendant to support his sentencing-disparities argument involved defendants whose conduct and criminal histories are distinguishable from defendant's. The court affirmed the judgment.
Court Description: Wollman, Author, with Melloy and Colloton, Circuit Judge] Criminal case - Sentencing. The district court's discussion of the 3553(a) factors, including those relied on by defendant, while brief, was sufficient to show the court was aware of the relevant factors and considered them before imposing sentence; the court adequately explained its sentencing decision; sentence was not substantively unreasonable.
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