Background
Macy Renee Patterson appealed her sentence following the revocation of her supervised release by the United States District Court for the Western District of Arkansas. She challenged the eighteen-month prison term as substantively unreasonable.
The court’s reasoning
The court concluded that the sentence was not substantively unreasonable because the record reflected that the district court adequately considered the relevant sentencing factors. The appellate court found no clear error of judgment in weighing factors and determined the district court did not give significant weight to an improper factor. The court noted the district court did not abuse its discretion by weighing relevant factors more heavily or varying upward due to Patterson’s poor performance on supervised release.
What it means going forward
This decision reinforces the deferential standard of review applied to sentencing decisions in the Eighth Circuit, confirming that appellate courts will not disturb sentences where the district court properly weighed relevant factors.