Background
Federico Luna appealed after the United States District Court for the Northern District of Iowa revoked his supervised release and sentenced him to twenty-four months in prison followed by twelve months of supervised release. His counsel moved for leave to withdraw and filed a brief challenging the substantive reasonableness of the revocation sentence.
The court’s reasoning
The court concluded that Luna’s within-Guidelines-range sentence was not unreasonable. The panel found no indication that the district court overlooked a relevant factor, gave significant weight to an improper or irrelevant factor, or committed a clear error of judgment in weighing the relevant factors. The court cited United States v. Phillips, noting that a revocation sentence within the Guidelines range is presumptively reasonable.
Upon careful review, we conclude that Luna’s within-Guidelines-range sentence was not unreasonable, as there is no indication the district court overlooked a relevant factor, gave significant weight to an improper or irrelevant factor, or committed a clear error of judgment in weighing the relevant factors.
United States v. Phillips, 785 F.3d 282, 284 (8th Cir. 2015)
What it means going forward
The decision reinforces the presumption of reasonableness for supervised release revocation sentences that fall within the Sentencing Guidelines range in the Eighth Circuit.