United States v. Lewis, No. 19-4028 (4th Cir. 2020)Annotate this Case
Defendant was convicted for possessing a firearm as a felon and sentenced to 63 months' imprisonment and a three-year period of supervised release. The district court additionally recommended, without explanation, that defendant receive addiction treatment while incarcerated and ordered, as a special condition of his supervised release, that defendant participate in an addiction treatment program.
The Fourth Circuit held that defendant's sentence is procedurally unreasonable because the district court failed to provide an adequate explanation for imposing as a special condition of supervised release the requirement of addiction treatment. The court also held that the district court failed to address defendant's nonfrivolous mitigation arguments. Therefore, the court remanded for resentencing.