Notable Third Circuit Booker ruling

The Third Circuit issued a substantial ruling on various post-Booker sentencing issues today in US v. Lloyd, No. 05-4241 (3d Cir. Nov. 28, 2006) (available here).  As is the common reality in every circuit after Booker, the defendant loses his appeal of a lengthy sentence.  Tellingly, even though the Third Circuit has not formally adopted a presumption of reasonableness for within-guideline sentences, the Lloyd court concludes its rejection of the defendant's claims by stressing that his "sentence was at the bottom of the guideline range and thus ... was more likely to be reasonable that one outside the guidelines range."