Daniel Ray Grimstead pleaded guilty in 2017 to unlawful possession of a firearm by a felon. He was initially sentenced to 50 months in prison followed by three years of supervised release. Over the next several years, Grimstead repeatedly violated the terms of his supervised release. In 2021 and 2023, the district court revoked his release twice, imposing shorter prison terms followed by additional supervised release. Following a final violation involving the use of controlled substances, failure to comply with drug testing and treatment, and the commission of new criminal offenses, the district court revoked his supervised release again. This time, the court sentenced Grimstead to 18 months of imprisonment with no additional term of supervised release. Grimstead appealed, and his counsel filed a brief pursuant to Anders v. California, concluding there were no meritorious issues for appeal but questioning whether the sentence was substantively unreasonable.
The Fourth Circuit reviewed the sentence under an abuse-of-discretion standard, noting that district courts have broad discretion when imposing sentences upon revocation of supervised release. The court explained that it will affirm a revocation sentence if it is within the statutory maximum and is not plainly unreasonable. Before determining if a sentence is plainly unreasonable, the court must first assess whether it is procedurally or substantively unreasonable. Procedural reasonableness requires that the district court adequately explains the chosen sentence after considering the Chapter Seven policy statement range and the applicable 18 U.S.C. § 3553(a) factors. While the court need not be as detailed as in post-conviction sentencing, it must provide a statement of reasons. Substantive reasonableness depends on whether the totality of the circumstances indicates a proper basis for the sentence. The appellate court concluded that the district court acted procedurally reasonably by properly calculating the policy statement range, providing the parties an opportunity to be heard, responding to sentencing arguments, and sufficiently explaining the chosen sentence. Furthermore, the court found that Grimstead failed to rebut the presumption of substantive reasonableness accorded to a sentence within the policy statement range. The court also reviewed the entire record in accordance with Anders and found no meritorious issues for appeal.
The conviction and sentence remain in effect without modification or remand. The decision reinforces the high deference appellate courts give to district courts in supervised release revocation cases, particularly when the sentence falls within the statutory and policy statement ranges. It clarifies that a defendant must present significant evidence to rebut the presumption of substantive reasonableness for such sentences. The court also dispensed with oral argument, noting that the facts and legal contentions were adequately presented in the written materials.