Holguin-Hernandez v. United States, 140 S. Ct. 762

Gonzalo Holguin-Hernandez was convicted of federal drug offenses, received 60 months' imprisonment plus five years' supervised release, and was already serving supervised release from an earlier conviction.
The Government sought revocation of the earlier supervised release and a consecutive sentence within the applicable Guidelines range (12–18 months).
Defense counsel argued under 18 U.S.C. §3553(a) that no additional time was warranted or, at minimum, any consecutive term should be less than 12 months (i.e., a sentence below the Guidelines).
The district court imposed a consecutive 12-month term (the bottom of the Guidelines range); defense raised nothing further at sentencing.
On appeal the Fifth Circuit held Holguin-Hernandez forfeited his challenge to the sentence’s substantive reasonableness because he did not explicitly object to the sentence as "unreasonable" at sentencing and affirmed.
The Supreme Court granted certiorari and held that advocating for a specific shorter sentence preserved the claim that the longer imposed sentence was "greater than necessary" under §3553(a).

Issue	Holguin-Hernandez's Argument	United States' Argument	Held
Whether a defendant preserves a substantive-reasonableness challenge by advocating for a specific shorter sentence at sentencing	Argued that requesting no additional time or less than 12 months communicated that a longer term would be "greater than necessary" under §3553(a), thus preserving the claim	Argued (and Fifth Circuit held) that the defendant forfeited the claim by failing to explicitly object to the sentence as "unreasonable" at sentencing	The Court held the argument was preserved: urging a specific shorter sentence ordinarily notifies the court that a longer sentence would be "greater than necessary," satisfying Rule 51(b)
Whether a defendant must use the word "reasonableness" or invoke the appellate standard of review to preserve a §3553(a)-based challenge	Not required; advocating for a shorter sentence suffices to bring the claim to the court's attention	The Government contended courts may require explicit reference to "reasonableness"	The Court rejected a requirement to use the label "reasonableness" or invoke appellate standards; Rule 51 abolishes formalistic language requirements

Kimbrough v. United States, 552 U.S. 85 (2007) (quoted "greater than necessary" language from §3553(a))
Pepper v. United States, 562 U.S. 476 (2011) (explains courts must impose sentences "sufficient, but not greater than necessary")
Gall v. United States, 552 U.S. 38 (2007) (reasonableness standard on appellate review of sentencing)
Booker v. United States, 543 U.S. 220 (2005) (sentencing discretion and appellate review principles)
Olano v. United States, 507 U.S. 725 (1993) (plain-error review framework)
Rita v. United States, 551 U.S. 338 (2007) (appellate review of within- and variances from Guidelines)
Tapia v. United States, 564 U.S. 319 (2011) (procedural sentencing issues; cited as a matter the Court did not resolve)
Puckett v. United States, 556 U.S. 129 (2009) (describes interests served by the plain-error rule)