Background
Charles Allen appealed after the district court revoked his supervised release and sentenced him to twenty-one months in prison followed by five years of supervised release. His counsel moved to withdraw and challenged the substantive reasonableness of the revocation sentence.
The court’s reasoning
The court concluded that the district court did not abuse its discretion because there was no indication it overlooked a relevant factor, gave significant weight to an improper factor, or committed a clear error of judgment. The sentence was within the Guidelines range and therefore afforded a presumption of substantive reasonableness.
What it means going forward
The decision reinforces the presumption of reasonableness for sentences within the Guidelines range during supervised release revocation proceedings.
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