Background
The defendant appealed a thirty-seven-month prison term imposed after the revocation of his supervised release. He argued the district court plainly erred by relying on retribution for his underlying offense, which violates the Supreme Court’s decision in Esteras versus the United States.
The court’s reasoning
The court applied plain-error review because the defendant failed to object at sentencing. While the district court improperly considered retribution, the defendant could not show this affected his substantial rights. The district court provided other valid reasons for the sentence, including deterrence and the seriousness of new state charges involving a machete.
threatening someone with a machete is life-threatening, so it should be treated seriously, and the Court intends to do that.
Opinion of the Court at 4
What it means going forward
Defendants must object to sentencing errors at the district court level to avoid plain-error review. Even if an error occurs, the sentence will stand if the court provided other sufficient reasons for the punishment.
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