United States v. Adrian Trone
690 F. App'x 654
| 11th Cir. | 2017Background
- Adrian Trone appealed after the district court revoked his supervised release and imposed an 18‑month prison term.
- Trone had previously served 10 months’ imprisonment for a prior supervised‑release violation.
- The revocation statute requires the district court to consider specified 18 U.S.C. § 3553(a) factors when imposing a sentence on revocation.
- Trone argued the 18‑month sentence was substantively unreasonable.
- The Eleventh Circuit reviews revocations for abuse of discretion and sentences for reasonableness; the challenger bears the burden of showing unreasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence was substantively unreasonable | Trone: sentence excessive and unjustified | Government: sentence within discretion and justified by deterrence/recidivism | Affirmed — not substantively unreasonable |
| Whether the court improperly relied on deterrence | Trone: court overemphasized deterrence | Court: deterrence proper given repeat violation after prior prison term | Reliance on deterrence justified |
| Whether the court failed to consider pertinent § 3553(a) factors | Trone: court ignored mitigating considerations (e.g., limited punishment for marijuana) | Court: judge acknowledged time served and heard arguments about marijuana offenses | Court considered relevant factors sufficiently |
| Whether the sentence rested on impermissible factors | Trone: alleged improper factors | Government: reliance was on permissible deterrence and recidivism concerns | No impermissible factors; sentence valid |
Key Cases Cited
- United States v. Velasquez Velasquez, 524 F.3d 1248 (11th Cir. 2008) (standard of review for supervised‑release revocation and sentence reasonableness)
- United States v. Sarras, 575 F.3d 1191 (11th Cir. 2009) (burden on challenger to show sentence unreasonable; guideline sentences ordinarily reasonable)
- Gall v. United States, 552 U.S. 38 (2007) (substantive‑reasonableness review considers totality of circumstances)
- United States v. Clay, 483 F.3d 739 (11th Cir. 2007) (district court has discretion in weighing § 3553(a) factors)
- United States v. Snipes, 611 F.3d 855 (11th Cir. 2010) (district court need not explicitly address every mitigating factor for sentence to be reasonable)