United States v. Lacresha Slappy

After serving a prison term, Slappy began serving a term of supervised release. Approximately one year later, Slappy’s probation officer filed a motion for revocation of Slappy’s supervised release, arguing numerous violations. At the revocation hearing, the Judge sentenced Slappy to the maximum punishment for these violations, while not specifically addressing a number of Slappy’s non-frivolous arguments in favor of a more lenient sentence. The Fourth Circuit notes that although the “court need not be as detailed or specific when imposing a revocation sentence as it must be when imposing a post-conviction sentence, . . . it still ‘must provide a statement of reasons for the sentence imposed.'” In light of that, the Fourth Circuit holds that the district court’s failure to address Slappy’s arguments in favor of a within-policy-statement-range sentence constitutes procedural error.

Accordingly, we apply Carter here and hold that a district court, when imposing a revocation sentence, must address the parties’ nonfrivolous arguments in favor of a particular sentence, and if the court rejects those arguments, it must explain why in a detailed-enough manner that this Court can meaningfully consider the procedural reasonableness of the revocation sentence imposed.

The Fourth Circuit concludes by holding that the district court’s error was not harmless. Consequently, Slappy’s sentence was vacated, and the case was remanded.

Read the full opinion here.

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