Background
Toni Yeager appealed her sentence after pleading guilty to a drug offense pursuant to a written plea agreement. Her counsel moved to withdraw and filed a brief challenging the substantive reasonableness of the sentence under Anders v. California.
The court’s reasoning
The court concluded that the district court did not abuse its discretion in sentencing Yeager. Citing United States v. Feemster, the court applied the abuse of discretion standard. The court also noted that the district court is presumed to have considered mitigating factors and that a within-Guidelines range sentence may be presumed reasonable. After an independent review under Penson v. Ohio, the court found no non-frivolous issues for appeal.
What it means going forward
The sentence imposed on Yeager stands, and her appointed counsel is permitted to withdraw from the case.
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