United States v. Anthony Vaughn, 17-1272

Anthony Vaughn pleaded guilty in 2005 to possession with intent to distribute methamphetamine; sentenced to 78 months custody and five years supervised release.
Vaughn repeatedly violated supervised-release conditions (marijuana and methamphetamine possession; later absconding and other technical violations) and received multiple revocations with custodial sentences and continued supervision.
In 2013 and thereafter Vaughn received warnings that future revocations could lead to maximum statutory penalties; in 2016 he left his district without permission, absconded to Indianapolis, and engaged in a two-hour standoff with law enforcement when found.
He was charged with ten violations (three dismissed); seven Grade C violations remained, yielding a Guidelines range of 3–9 months (Criminal History I) and a statutory maximum of five years.
The district court held a lengthy hearing, adopted the probation officer’s recommendation, and imposed an above-Guidelines 24‑month custodial sentence with no further supervision, citing the need to vindicate respect for the law and sanction absconding.
Vaughn appealed, arguing the 24‑month sentence was substantively unreasonable and lacked sufficient relation to § 3553(a) factors; the Sixth Circuit reviewed for abuse of discretion.

Issue	Vaughn's Argument	Government/District Court Argument	Held
Whether a 24‑month sentence for Grade C supervised‑release violations is substantively unreasonable	24 months bears no quantifiable relation to §3553(a); district relied on prior warning and retribution; variance is unjustified	District court considered §3553(a), explained need to sanction absconding and vindicate respect for law; substantial justification for upward variance	Affirmed — no abuse of discretion; district adequately articulated reasons and balanced factors
Whether district court failed to consider Guidelines range and relevant factors	Sentence arbitrary and unlinked to Guidelines	Court expressly considered Guidelines, testimony, recidivism, and need to promote respect for law	Held that court considered pertinent factors and did not act arbitrarily
Whether reliance on prior statement of intent to punish was improper	Prior statement showed predetermination and impermissible retribution	Prior warning was one factor among many; court gave individualized, reasoned explanation	Held acceptable; not sole or impermissible basis for variance
Whether Yopp requires vacatur of this sentence	Cites Yopp where 24 months vacated because district gave no articulated basis	Distinguishes Yopp: here court articulated substantial justification and considered policy statements	Held Yopp not controlling; sentence upheld

United States v. Yancy, 725 F.3d 596 (6th Cir. 2013) (standard of appellate review for revocation sentencing)
United States v. Bolds, 511 F.3d 568 (6th Cir. 2007) (applying abuse‑of‑discretion review to revocation sentences)
United States v. Brown, 501 F.3d 722 (6th Cir. 2007) (factors rendering a sentence substantively unreasonable)
Gall v. United States, 552 U.S. 38 (2007) (standards for appellate review of variance and reasoned justification requirement)
United States v. Yopp, 453 F.3d 770 (6th Cir. 2006) (vacating a 24‑month revocation sentence due to absence of articulated basis)
United States v. Richards, 659 F.3d 527 (6th Cir. 2011) (district courts need not use rigid formulas when explaining variances)