United States v. Amono Washington, 2014 U.S. App. LEXIS 1015

Washington pleaded guilty to attempting to possess cocaine with intent to distribute; approximately 1.765 kilograms of cocaine were seized at a suspected drug dealer's residence.
DEA arrested Washington in March 2010; he admitted attempting to purchase the cocaine.
District court calculated a sentencing guidelines range of 97 to 121 months and sentenced Washington to 97 months.
The court stated it had “considered all the factors of 18 U.S.C. § 3553(a)” and noted the crime was serious, but gave a terse, general explanation for the term.
Presentence report indicated Washington lacked immediate ability to pay a fine but could pay later through the Inmate Financial Responsibility Program or during supervised release; court also imposed a $500 fine.
Court of Appeals remanded for resentencing due to inadequate explanation of the chosen sentence and did not disturb the fine despite it being below guidelines.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court adequately explained the 97-month sentence.	Washington	Government	Remand for independent justification
Whether the court must provide independent justification for a within-guidelines sentence.	Washington	Government	Remand for resentencing with proper justification

Gall v. United States, 552 U.S. 38 (U.S. 2007) (requires explanation to permit meaningful appellate review)
Rita v. United States, 553 U.S. 338 (U.S. 2007) (within-guidelines sentencing requires consideration of § 3553(a) factors)
Lyons v. United States, 733 F.3d 777 (7th Cir. 2013) (within-guidelines sentences require independent justification at times)
Garcia-Oliveros v. United States, 639 F.3d 380 (7th Cir. 2011) (explains need for individualized assessment for sentence)
United States v. Shannon, 518 F.3d 494 (7th Cir. 2008) (within-guidelines review not strictly checklist-based)
Tapia v. United States, 131 S. Ct. 2382 (S. Ct. 2011) (rehabilitation cannot justify imprisonment)