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Fourth Circuit to District Court: Explain Yourself

By Robyn Hagan Cain on September 27, 2012 | Last updated on March 21, 2019

There's a time to be coy. A time to bat your lashes coquettishly and flirtatiously allude to your thoughts, or reasoning, or motivation.

Sentencing is not that time, according to the Fourth Circuit Court of Appeals.

Joel Dallas Bonner pleaded guilty to possession of cocaine and being a felon in possession of a firearm. The district court imposed a sentence of 151 months on the drug charge and a mandatory minimum 120-month term on the firearm charge.

On appeal, Bonner argued that his sentence was procedurally unreasonable because the court did not sufficiently explain the basis for the sentence imposed. The Fourth Circuit agreed, in an unpublished opinion.

An appellate court reviews a sentence for reasonableness, using an abuse of discretion standard of review. The first step in this review requires the court to ensure that the district court committed no significant procedural error. Procedural errors include failing to calculate (or improperly calculating) the Sentencing Guidelines range, treating the Guidelines as mandatory, failing to consider statutory sentencing factors, selecting a sentence based on clearly erroneous facts, or failing to adequately explain the chosen sentence - including an explanation for any deviation from the Guidelines range.

Specifically, "the district court must state in open court the particular reasons supporting its chosen sentence [and] set forth enough to satisfy the appellate court that [it] has considered the parties' arguments and has a reasoned basis for exercising [its] own legal decision-making authority."

Here, the appellate court concluded that the district court erred because it failed to explain why it imposed the chosen sentence: The district court didn't address Bonner's argument in favor of a sentence below the Guidelines range, and it didn't provide any reasons for choosing the sentence imposed.

A district court must explain its reasoning for a sentence, plain and simple. If you represent a client who was sentenced in a similarly ambiguous manner, you'll probably win a second date with the district court on appeal.

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