Background
Deion Tyrell Liles appealed consolidated cases from the Middle District of North Carolina. He challenged a sixty-six-month sentence for possessing a firearm as a convicted felon and two sentences imposed upon the revocation of his supervised release. His attorney filed a brief pursuant to Anders v. California, questioning the reasonableness of the sentences and alleging the district court found violations the government did not pursue.
The court’s reasoning
The court reviewed the sentences for abuse of discretion, finding the district court properly calculated the Guidelines range and adequately explained the upward variance. Regarding supervised release, the court found no error in revocation after Liles admitted to a new federal offense. However, the court identified a clerical error in the judgment reflecting eight violations, including three the government did not pursue, and ordered correction under Federal Rule of Criminal Procedure thirty-six.
What it means going forward
The decision reinforces the Fourth Circuit’s deferential standard for reviewing criminal sentences and supervised release revocations while providing a mechanism to correct clerical errors in judgments that misstate the number of violations found.
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