United States v. Angela Carrino, 697 F. App'x 884

Angela Marie Carrino pled guilty in 2014 to one count of conspiracy to deliver firearms (18 U.S.C. § 371) in the N.D. of Illinois and was sentenced to 4 years probation with initial community confinement and home confinement.
Jurisdiction transferred to the E.D. of Missouri, where Carrino served probation and accumulated numerous violations from Sept 2014 onward: positive drug tests, driving violations (including a later DWI arrest), missed urinalysis, failure to attend substance-abuse counseling, and RRC rule violations.
At a revocation hearing Carrino admitted the violations; the district court revoked probation and sentenced her to 16 months imprisonment followed by 36 months supervised release.
Carrino appealed, arguing (1) the sentence was substantively unreasonable because the court failed to account sufficiently for her mental-health and substance-abuse issues and (2) the court failed to credit days she spent in official detention against the new sentence.
The Eighth Circuit reviewed for abuse of discretion and affirmed, concluding the district court considered the § 3553(a) factors and permissibly weighed Carrino’s repeated substance use, treatment noncompliance, and recent DWI in imposing a below-alternative-range term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation sentence was substantively unreasonable for failing to account for mental-health/substance-abuse	Carrino: court did not adequately consider her mental-health and addiction as mitigation for violations	Government: court considered these factors but reasonably emphasized repeated substance use, treatment failures, and recent DWI	Affirmed — no abuse of discretion; court adequately considered § 3553(a) factors and permissibly weighed violations
Whether court erred by imposing a sentence above advisory revocation Guidelines range	Carrino: sentence harsher than advisory range (3–9 months) was unreasonable	Government: district court may consider original offense exposure and alternative ranges; it substantially varied downward from the higher available range	Affirmed — within district court discretion; downward variance from statutory alternative was reasonable
Whether district court should have adjusted sentence for days in official detention pre-sentencing	Carrino: court should have reduced sentence to reflect time in prior custody because BOP credit calculations might differ	Government: district court is not responsible for computing BOP credit under 18 U.S.C. § 3585(b)	Affirmed — district court not required to compute or anticipate BOP credit; credit calculation occurs after imprisonment begins

United States v. Keatings, 787 F.3d 1197 (8th Cir.) (abuse-of-discretion standard for revocation sentencing)
United States v. Feemster, 572 F.3d 455 (8th Cir.) (standards for substantive-reasonableness review)
United States v. Larison, 432 F.3d 921 (8th Cir.) (deference to district court concern over repeated violations and treatment failures)
United States v. Pardue, 363 F.3d 695 (8th Cir.) (district court cannot apply § 3585(b) at sentencing)
United States v. Wilson, 503 U.S. 329 (Sup. Ct.) (credit computation occurs after sentence begins)