United States v. Camron Witkowski
687 F. App'x 251
| 4th Cir. | 2017Background
- Appellant Camron Witkowski appealed the district court’s revocation of his supervised release and imposition of a 15‑month prison term followed by 45 months supervised release.
- Counsel filed an Anders brief stating no meritorious issues but questioned whether the sentence was plainly unreasonable; Witkowski received notice of the right to file a pro se brief and did not do so.
- The Government declined to file a response brief.
- The Fourth Circuit reviewed the record under the standard for supervised‑release revocation sentences (procedural and substantive reasonableness, then plain‑error/plain‑unreasonableness review if necessary).
- The Fourth Circuit concluded the sentence was within the statutory range and not plainly unreasonable and affirmed the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 15‑month revocation sentence was plainly unreasonable | Witkowski (via counsel) suggested the sentence might be plainly unreasonable | Government defended the revocation sentence; district court relied on permitted factors and Guidelines Chapter 7 | Court held sentence was within statutory range, not plainly unreasonable, and affirmed |
| Whether counsel satisfied Anders obligations | Counsel filed an Anders brief asserting no meritorious issues and questioned reasonableness | Appellate court to review entire record for meritorious issues; Witkowski did not file pro se brief | Court found counsel’s Anders submission sufficient after review and identified no meritorious issues |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (procedure for counsel’s assertion that an appeal is frivolous)
- United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (standards for procedural, substantive, and plain‑unreasonable review of revocation sentences)