United States v. Williams, No. 20-4120 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed defendant's sentence of 327 months' imprisonment imposed after he pleaded guilty to producing child pornography, as well as his within-Guidelines lifetime term of supervised release.
The court concluded that defendants' sentence was procedurally reasonable where the district court imposed an upward variance, rather than a Guidelines departure, and thus notice was not required. The court rejected defendant's contention that the district court's reliance on the victim's self-harm and mental health problems prejudiced him because he lacked access to her medical records. Furthermore, the court found the district court's explanation entirely adequate to support the lifetime term of supervised release, especially in context of the parties' arguments. The court also found no reversible procedural error in the district court's pronouncement of the special conditions for defendant's supervised release. Finally, the court concluded that defendant's sentence was substantively reasonable and the district court did not abuse its discretion in sentencing defendant 5 years above the Guidelines range. Nor was the term of supervised release substantively unreasonable.