United States v. Alain Belizaire, 20-10797

On Dec. 4, 2019, Alain Belizaire pled guilty to one count of conspiracy to possess with intent to distribute cocaine, crack, fentanyl, and marijuana (21 U.S.C. §§ 841(b)(1)(C), 846).
The district court sentenced Belizaire to 240 months' imprisonment followed by three years of supervised release.
Belizaire challenged the sentence as substantively unreasonable under 18 U.S.C. § 3553(a), arguing it was greater than necessary to achieve sentencing goals.
The district court considered the offense’s nature and seriousness, Belizaire’s remorse and ongoing cooperation (which had not produced arrests), and that the offense resulted in a death, and imposed a within-guidelines 240-month sentence.
The Eleventh Circuit reviews substantive reasonableness for abuse of discretion; the challenger bears the burden to show unreasonableness in light of the record, § 3553(a) factors, and deference to the sentencing court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 240-month sentence is substantively unreasonable under § 3553(a)	Belizaire: sentence is greater than necessary; court failed to impose the least-restrictive sufficient sentence	Government/District court: court considered § 3553(a) factors, properly weighed seriousness and outcome; sentence is within guidelines and discretionary	Affirmed: sentence not substantively unreasonable; district court adequately considered factors and did not abuse discretion

Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion standard for reviewing substantive reasonableness of a sentence)
United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015) (burden on appellant to show sentence unreasonable; deference to sentencing court's weighing of § 3553(a) factors)
United States v. Gonzalez, 550 F.3d 1319 (11th Cir. 2008) (district court need not explicitly address every § 3553(a) factor; acknowledgment suffices)