United States v. Archie Goodman, 713 F. App'x 290

In 2012 Goodman pled guilty to possession of stolen mail and aiding and abetting; sentenced to 21 months, 3 years supervised release, and restitution.
Goodman’s supervised release had been revoked three times prior to 2016.
In 2016 a probation officer filed a petition alleging four supervised-release violations; the district court revoked release and imposed the 24‑month statutory maximum revocation sentence (no additional supervised release).
Goodman appealed, arguing (1) the district court improperly relied on forbidden § 3553(a)(2)(A) factors when imposing revocation sentence, (2) the court failed adequately to explain the employment-violation finding, and (3) his arrest warrant was invalid for lack of sworn facts.
Goodman did not raise the sentencing‑factor objection below, so appellate review was for plain error only.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court improperly relied on § 3553(a)(2)(A) (need for just punishment, respect for law, seriousness) in choosing sentence	Goodman: court considered forbidden § 3553(a)(2)(A) factors, requiring reversal	Government/district court: comments reflect permissible considerations (deterrence) and other legitimate factors; any error was not plain or dominant	Affirmed — no plain error; record shows permissible factors (deterrence) and any improper consideration was not a dominant factor
Whether district court inadequately explained finding that Goodman failed to maintain employment	Goodman: court’s finding lacked sufficient explanation and relied on allegations only	Government: hearing record shows Goodman admitted lack of employment after Oct 8, 2016, so finding was supported; any absence of detailed reasons was harmless	Affirmed — revocation supported by the record; lack of specific explanation was harmless
Whether arrest warrant was invalid for lack of sworn facts	Goodman: warrant invalid under Vargas‑Amaya because not supported by sworn facts	Government: Fifth Circuit precedent forecloses this argument	Affirmed — argument is foreclosed by Garcia‑Avalino

United States v. Whitelaw, 580 F.3d 256 (5th Cir. 2009) (plain‑error standard when issue not raised below)
Puckett v. United States, 556 U.S. 129 (U.S. 2009) (plain‑error framework: clear or obvious error affecting substantial rights)
United States v. Miller, 634 F.3d 841 (5th Cir. 2011) (prohibits revocation sentences based on certain § 3553(a)(2)(A) factors)
United States v. Rivera, 784 F.3d 1012 (5th Cir. 2015) (distinguishes dominant vs. secondary consideration of forbidden factors)
United States v. Gonzalez‑Perez, [citation="537 F. App'x 589"] (5th Cir. 2013) (application of plain‑error analysis to sentencing factor claims)
United States v. McCormick, 54 F.3d 214 (5th Cir. 1995) (harmlessness of inadequate explanation when reasons for revocation are obvious)
United States v. Garcia‑Avalino, 444 F.3d 444 (5th Cir. 2006) (foreclosing Vargas‑Amaya challenge in Fifth Circuit)
United States v. Vargas‑Amaya, 389 F.3d 901 (9th Cir. 2004) (warrant‑validity rule relied on by Goodman)