USA v. Henry Martin Steiger, No. 22-10742 (11th Cir. 2023)
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Defendant appealed his sentence of 20 years of imprisonment following the revocation of his probation pursuant to 18 U.S.C. Section 3565. Defendant argued that, where the Sentencing Guidelines recommended a sentence of 12 to 18 months of imprisonment, his sentence is procedurally and substantively unreasonable. One of his arguments is that the district court failed to give a specific reason for imposing an upward variance to the statutory maximum.
The Eleventh Circuit vacated and remanded for resentencing. The court wrote that upon finding that a defendant violated a condition of probation, a district court may revoke the term of probation and impose a term of imprisonment as long as the court considers the factors set forth in 18 U.S.C. Section 3553(a), such as the need for the sentence imposed to reflect the “seriousness of the offense” and “afford adequate deterrence,” among others. The court noted that a district court commits a “significant procedural error” in imposing a sentence if it calculates the guidelines incorrectly, fails to consider the Section 3553(a) factors, bases the sentence on clearly erroneous facts, or, of particular relevance here, “fail[s] to adequately explain the chosen sentence—including an explanation for any deviation from the Guidelines range.” The court explained that the record reflects that the district court did not give any reason for why it was imposing an above-guideline sentence. The court explained that the district court’s statements at the conclusion of the revocation proceeding were not sufficiently specific to allow the court to understand why the district court imposed an above-guideline sentence.
The court issued a subsequent related opinion or order on November 27, 2023.
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