Kendall Guyton pleaded guilty to sex trafficking after engaging in a criminal operation from 2017 to 2020 where he recruited women, exploited their drug addictions, and controlled their earnings through violence and abuse. He was sentenced to 324 months in prison and ordered to pay $105,000 in restitution. The district court had corrected an error in Guyton's criminal history calculation during sentencing, placing him in Category V rather than Category VI, but Guyton confirmed at the hearing that he had no objection to the final guidelines range or the application of the vulnerable victim enhancement. Guyton appealed, but his appointed counsel filed an Anders motion asserting that the appeal was frivolous because Guyton had waived his right to challenge the guidelines calculation and the sentence was substantively reasonable.
The court limited its review to the issues discussed by counsel, as required when counsel moves to withdraw under Anders v. California. The court found that Guyton waived any procedural challenge to the sentencing guidelines calculation because he explicitly confirmed the revised criminal history category and the application of the vulnerable victim enhancement at the sentencing hearing. Regarding the substantive reasonableness of the sentence, the court noted that Guyton received a within-guidelines sentence, which creates a presumption of reasonableness that the record could not rebut. The district court had properly considered the Section 3553(a) factors, including the nature of the offense, the need to protect the public, and the goal of avoiding unwarranted sentencing disparities with Guyton's codefendant. The court also found that Guyton waived any challenge to the restitution order by stating he had no objection to the amount imposed.
The appeal is dismissed, leaving the 324-month sentence and restitution order in place. The decision reinforces that defendants who confirm sentencing calculations and enhancements at the hearing generally waive the right to appeal those specific issues. It also confirms that within-guidelines sentences supported by a thorough explanation of statutory factors are difficult to overturn on substantive reasonableness grounds.
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