Background
Jermaine Jerome Campbell pleaded guilty to possession with intent to distribute fentanyl and methamphetamine. The district court calculated an advisory guideline range of one hundred eighty-eight to two hundred thirty-five months. Campbell argued for a lower sentence based on childhood trauma and requested a review of comparators outside the Middle District of Florida.
The court’s reasoning
The court reviewed the sentence for plain error regarding procedural reasonableness. It found that Campbell’s general objection did not preserve the specific issue of geographic limitations on comparators. The court determined that no rule or precedent required the district court to consider out-of-district cases. Regarding substantive reasonableness, the court found the sentence was within the district court’s discretion and accounted for the defendant’s background and the need to avoid unwarranted disparities.
What it means going forward
The ruling reinforces that defendants must raise specific objections to preserve sentencing disparity arguments involving geographic limitations on comparators.