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June 28, 2006

A batch of reasonableness rulings

Not long after I did this post about quiet Booker times, I saw noteworthy sentencing opinions in three circuits.  AL&P has the (unpublished) action in the First Circuit well covered here and here and here, so I'll focus on rulings from the Fifth and Eleventh Circuits.

The Fifth Circuit gives the government two reasonableness wins in US vs. Candia, No. 05-30213 (8th Cir. June 28, 2006) (available here) (affirming as reasonable application of consecutive sentences); US vs. Medina-Argueta, No. 05-50474 (8th Cir. June 28, 2006) (available here) (affirming  sentences as reasonable despite guideline calculation error harming defendant).

Meanwhile, the Eleventh Circuit gives the government a major reasonableness defeat in US vs. Gray, No. 05-30213 (11th Cir. June 28, 2006) (available here), by affirming a sentence imposed significantly below the guidelines range.  Here's the key concluding paragraph:

[T]he district court gave specific, valid reasons for imposing a sentence that was lower than the guidelines range.  The court's statements at sentencing reflect that it took into account Gray's age, his prior minimal criminal record, and his medical condition. These are all valid considerations because they relate to the "history and characteristics of the defendant."  The court weighed these factors against "the nature and circumstances of the offense" and decided to impose a nonguidelines sentence. There is no indication that the court imposed the lower sentence solely because it disagreed with the guidelines.  Rather, the court's statements show that it believed the 72-month sentence to be reasonable.  Although Gray's sentence is less than half the 151 months that defines the bottom of the guidelines range, under the circumstances and given the district court's explanation we cannot say that is unreasonable in light of the § 3553(a) factors.

June 28, 2006 at 10:40 PM | Permalink


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