Background
Rashad Jamal Blanchard pled guilty to possession with intent to distribute at least fifty grams of methamphetamine. The district court imposed a sentence of twenty-four months imprisonment followed by five years of supervised release. Blanchard’s counsel filed an Anders brief asserting no meritorious grounds for appeal but questioning the waiver and the sentence’s reasonableness.
The court’s reasoning
The court reviewed the sentence for procedural and substantive reasonableness under Section thirty-five fifty-three of Title eighteen. It found the district court correctly calculated the Guidelines range and considered all relevant factors. The court noted Blanchard’s increasingly violent criminal history, including carjacking and bank robbery, as justification for the sentence. The court concluded Blanchard failed to rebut the presumption of reasonableness accorded to his below-Guidelines sentence.
We thus conclude that Blanchard fails to rebut the presumption of reasonableness accorded his below-Guidelines sentence.
United States v. Blanchard, 24-4631 (4th Cir. 2026)
What it means going forward
The decision reinforces the Fourth Circuit’s deference to district courts when imposing below-Guidelines sentences for defendants with violent criminal histories.