United States v. Carlton Styles, 20-13321

Styles pleaded guilty to Hobbs Act robbery; originally sentenced as a career offender but this Court vacated that designation in United States v. Eason and remanded for resentencing.
On resentencing the PSR calculated offense level 22, criminal-history category IV, yielding a Guidelines range of 63–78 months; statutory maximum was 20 years.
The government sought an upward variance based on Styles’s criminal history and to avoid unwarranted disparities with co-defendants; several co-defendants had received substantially higher sentences.
The district court adopted the PSR, considered § 3553(a) factors (both mitigation and aggravation), and imposed a 151-month sentence (an upward variance).
Styles argued on appeal that the sentence was procedurally and substantively unreasonable: the court relied on sealed co-defendants’ PSRs, double-counted criminal history, overemphasized disparity avoidance, and failed to adequately account for mitigating factors.
The Eleventh Circuit affirmed, applying abuse-of-discretion review and finding no procedural or substantive error.

Issue	Plaintiff's Argument (Styles)	Defendant's Argument (Government/District Court)	Held
Use of co-defendants' sealed PSRs	Court improperly relied on nonpublic PSR material and should have ordered disclosure	Court permissibly considered disparity concerns; Styles never moved to unseal or objected to disclosure	Affirmed — no rule/precedent required sua sponte unsealing; Styles didn’t preserve a right to relief
Reliance on prior robbery already counted in Guidelines	Court double-counted criminal history by varying upward for the same facts scored in criminal-history points	A court may rely on a factor accounted for in Guidelines if it explains why this defendant differs from the ordinary case	Affirmed — court explained the ‘‘eerily similar’’ prior robbery and why this case differed
Weight given to avoiding unwarranted sentencing disparities	Court placed excessive weight on disparities with co-defendants	Avoiding unwarranted disparities is a valid §3553(a) factor and the court properly considered co-defendants’ sentences and histories	Affirmed — no clear error in the court’s balancing of §3553(a) factors
Adequacy of the district court’s explanation for the upward variance	Explanation insufficient to permit meaningful appellate review	Court gave an extensive, specific §3553(a) analysis (rehab, danger, escalation, similar prior robbery, disparity concerns)	Affirmed — procedural explanation adequate; variance justified under §3553(a)

United States v. Eason, 953 F.3d 1184 (11th Cir. 2020) (vacating career-offender designation for Hobbs Act robbery)
Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review of sentencing reasonableness)
United States v. Rodriguez, 628 F.3d 1258 (11th Cir. 2010) (sentence must be procedurally and substantively reasonable)
United States v. Wayerski, 624 F.3d 1342 (11th Cir. 2010) (procedural-reasonableness checklist)
United States v. Shaw, 560 F.3d 1230 (11th Cir. 2009) (explanation required for variances)
United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015) (abuse-of-discretion standard for substantive reasonableness)
United States v. Goldman, 953 F.3d 1213 (11th Cir. 2020) (deference to district court’s weighing of §3553(a) factors)
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) (framework for vacatur only for clear error in weighing)
United States v. Lejarde-Rada, 319 F.3d 1288 (11th Cir. 2003) (plain-error review when issues not raised below)
United States v. Zapete-Garcia, 447 F.3d 57 (1st Cir. 2006) (permitting consideration of factors already in Guidelines when individualized explanation provided)
United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014) (preservation and plain-error sentencing review)
United States v. Whitesell, 314 F.3d 1251 (11th Cir. 2002) (procedural defaults on appeal)