United States v. Anthony Geppi, 698 F. App'x 83

Anthony Salvador Geppi appealed the district court’s revocation of supervised release and a 22-month prison sentence.
Counsel filed an Anders brief stating no meritorious issues but questioned whether the sentence was plainly unreasonable; the Government declined to file a brief and Geppi filed no pro se brief.
The district court imposed 22 months (within the 23-month statutory maximum) and terminated supervised release thereafter.
The court explained Geppi displayed a pattern of continuing criminal conduct and was unsuitable for supervision, and stated it considered the applicable § 3553(a) factors and Chapter 7 policy statements.
The Fourth Circuit reviewed the record under the plain-unreasonableness standard applicable to supervised-release revocation sentences and conducted the required Anders review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sentence was plainly unreasonable	Geppi (through counsel) questioned plain unreasonableness of 22-month term	Government defended district court’s discretion; district court cited pattern of conduct and statutory limits	Affirmed — sentence not plainly unreasonable
Whether district court considered required factors	Implied challenge that court might not have fully considered § 3553(a) and Chapter 7	District court stated it considered permissible § 3553(a) factors and Chapter 7 policy statements	Affirmed — court adequately considered required factors
Procedural reasonableness of revocation sentence	Implied concern about procedural adequacy under Crudup framework	District court followed procedural requirements and explained basis for sentence	Affirmed — procedurally reasonable
Substantive reasonableness of revocation sentence	Implied concern sentence may be substantively excessive	District court cited defendant’s ongoing criminal conduct and unsuitability for supervision; sentence within statutory max	Affirmed — substantively reasonable

Anders v. California, 386 U.S. 738 (1967) (procedures for counsel to follow when presenting an appeal as frivolous)
United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (standards for reviewing supervised-release revocation sentences)