Background
Yonathan Melaku was originally sentenced to twenty-five years for firing at military sites and possessing bomb-making materials. After a prior appeal vacated one count of his conviction, the district court resentenced him to a total of twenty years. Melaku raised four challenges on appeal, including claims that the sentence was imposed to ensure his medical compliance and that the court lacked jurisdiction to order a pre-release hearing.
The court’s reasoning
The court held that two of Melaku’s challenges were forfeited because he failed to object at the sentencing hearing. For the forfeited Tapia claim, the court found no clear or obvious error because settled law does not prohibit considering a defendant’s need for medical care for an incurable condition like schizophrenia, nor does it bar imposing a sentence to protect the public from an unmedicated defendant. The court also rejected procedural and substantive reasonableness challenges, finding the district court’s sentence justified by the dangerous nature of Melaku’s conduct and his history of non-compliance with treatment. Finally, the court dismissed the jurisdictional argument as forfeited and mischaracterized, noting the district court retained remedial authority over a defendant still serving its sentence.
No procedural principle is more familiar than that an argument may be forfeited in criminal as well as civil cases by the failure to make timely assertion of the argument before a tribunal having jurisdiction to determine it.
Yakus v. United States, 321 U.S. 414, 444 (1944)
What it means going forward
The decision reinforces that defendants must raise sentencing objections at the time of the hearing to preserve them for appeal. It clarifies that federal courts may consider a defendant’s medical needs and public safety risks when determining sentence length without violating the Tapia prohibition on using imprisonment to promote rehabilitation.