USA v. Frederick Miller, No. 20-3084 (D.C. Cir. 2022)
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The district court sentenced Appellant to life imprisonment, concluding that a sentence within the Sentencing Guidelines range did not reflect the seriousness of Appellant’s crimes or act as a sufficient deterrence. Appellant argued that the district court exceeded the scope of its resentencing mandate and committed procedural and substantive errors in imposing the life sentence. The DC Circuit affirmed Appellant’s life sentence finding that the district court did not commit a procedural and substantive error. The court further remanded for the correction of several clerical errors in the judgment.
The court first considered whether the district court committed a “significant procedural error,” such as improperly calculating the Sentencing Guidelines range or relying on clearly erroneous facts. Here, the court rejected Appellant’s other claims of “significant” procedural error. First, the district court did not use the Guidelines as its basis for the upward variance. It explicitly applied the upward variance based on considerations required by 18 U.S.C. Section 3553(a), including the “nature and circumstances” and “seriousness” of the crimes.
Next, the court considered“the substantive reasonableness of the sentence” under the “abuse-of-discretion” standard, considering the “totality of the circumstances, including the extent of any variance from the Guidelines range.” Here, the court reasoned that the district court distinguished this case from a typical case with the same underlying charges. Further, Appellant's sentence properly considered the purposes of criminal sentencing.
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