United States v. Amos James, 705 F. App'x 207

Amos King James pled guilty to conspiring to distribute cocaine base, heroin, and dibutylone in violation of federal drug statutes.
District court sentenced James to 12 months’ imprisonment followed by a lifetime term of supervised release.
James challenged the lifetime supervised-release term as procedurally and substantively unreasonable on appeal.
The Fourth Circuit reviews sentencing for procedural and substantive reasonableness under an abuse-of-discretion standard and requires an individualized § 3553(a) assessment.
The appellate court found the district court failed to explain why lifetime supervised release was imposed and did not address James’s mitigating arguments (employment, CDL pursuit, childcare).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lifetime supervised-release term was procedurally reasonable	James: court failed to adequately explain or apply § 3553(a) factors and ignored nonfrivolous mitigating arguments	Government: district court considered § 3553(a) purposes and justified sentence based on recidivism risk after recent release	Vacated and remanded: district court procedurally erred by not explaining why lifetime supervision was imposed and failing to address key § 3553(a) factors and James’s arguments

Gall v. United States, 552 U.S. 38 (sets deferential abuse-of-discretion standard for sentencing review and requires consideration of § 3553(a) factors)
United States v. Evans, 159 F.3d 908 (treats supervised release as part of the sentence)
United States v. Helton, 782 F.3d 148 (court need not recite § 3553(a) factors robotically)
United States v. Carter, 564 F.3d 325 (requires individualized § 3553(a) assessment and explanation)
United States v. Bollinger, 798 F.3d 201 (district court should address nonfrivolous arguments for a different sentence)
United States v. Montes-Pineda, 445 F.3d 375 (context can sometimes show rationale but cannot substitute for an explicit explanation)