United States v. Reyes-Correa, No. 21-1913 (1st Cir. 2023)
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The First Circuit vacated Defendant's statutory maximum thirty-six-month sentence that the district court imposed following a revocation of supervised release, holding that the district court's failure adequately to justify the sentence was procedural error.
After a revocation hearing, the district court revoked Defendant's supervised release term for violations of the conditions of his release. The district court sentenced Defendant to thirty-six months' imprisonment, the statutory maximum for Defendant's violation. The First Circuit vacated the sentence and remanded the case for resentencing, holding that none of court's rationales explained why Defendant's case was so distinct from other such revocation cases that he deserved a 400 percent increase over the guidelines sentencing range.
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