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February 8, 2006

Eleventh Circuit remands unexplained life sentence

The Eleventh Circuit today in  US v. Williams, No. 04-14350 (11th Cir. Feb. 8, 2006) (available here) remanded a life sentence in a crack case because the district court failed to comply with its obligations under 18 U.S.C. § 3553(c)(1) to "state in open court the reasons for its imposition of the particular sentence, and, if the sentence . . . exceeds 24 months, the reason for imposing a sentence at a particular point within the range."  Here are highlights from Williams:

We focus exclusively on the "sufficiency" of the court's conduct at sentencing, not that of the defendant: "Congress has specifically proclaimed that a sentencing court shall state 'the reason for imposing a sentence [exceeding 24 months] at a particular point within the range.' . . . When a sentencing court fails to comply with this requirement, the sentence is imposed in violation of law . . . ." U.S. v. Veteto, 920 F.2d 823, 826 (11th Cir. 1991) (citations omitted) (emphasis added).

In Veteto we remanded for compliance with § 3553(c)(1) because the trial court explained a sentence in excess of 24 months with the "truism" that the chosen punishment "seem[ed] right."  Id. at 824, 826. Here the trial court offered no reason for the life sentence it elected to impose upon 26 year-old Williams. The duty of this Court in the instant case, then, is as clear as the explicit statutory duty imposed by § 3553(c)(1).

February 8, 2006 at 04:38 PM | Permalink


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