United States v. Brown, No. 20-1959 (1st Cir. 2022)
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The First Circuit affirmed the judgment of the district court convicting Defendant for conspiracy to commit an offense against the United States and other offenses and resentencing him to a 300-month sentence, holding that Defendant's sentence was substantively reasonable.
Defendant, who had been imprisoned for the last thirteen years for tax fraud and his role and an armed standoff with the U.S. Marshals Service, filed a second motion to vacate, set aside, or correct his sentence. The district court granted the motion and subsequently resentenced Defendant to a term that was 144 months below the prior sentence. Defendant appealed, raising two constitutional objections to his sentence and challenging the reasonableness of his sentence. The First Circuit affirmed, holding (1) Defendant's constitutional challenges were without merit; (2) there was no procedural error in the district court proceedings; and (3) the sentence imposed was substantively reasonable.
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