More examples of why district judges need to show their sentencing work

Just a few days after Booker was decided, I highlighted in this post the message from the US Sentencing Commission to sentencing judges to "Always remember to show your work."  Two circuit opinions at the end of last week reinforce this message some 30 months later.

In US v. Liou, No. 06-4405 (6th Cir. July 20, 2007) (available here), the Sixth Circuit affirms a district judge's choice of a within-guideline sentence because the "district court offered clear reasons for its sentence [having] articulated the various § 3553(a) factors and then identified the two factors it found most relevant."  Liou is also an important ruling because it provides one of the first extended circuit discussions of the Supreme Court's work in Rita.

In US vs. Lawson, No. 06-3035 (DC Cir. July 20, 2007) (available here), the DC Circuit has to vacate and remand a sentence because "the record is muddled as to whether the district court considered [a particular guideline range as the] starting point for its analysis."  The Lawson court explains that "[w]ithout knowing the point at which the sentencing court began its calculation, we cannot address Lawson's argument that his was unreasonable."