United States v. Caroll Young
693 F. App'x 361
| 5th Cir. | 2017Background
- Caroll Andrew Young appealed an 18-month prison sentence and 18 months supervised release imposed after revocation of his supervised release.
- District court revoked Young’s supervised release based in part on failure to obtain an AA sponsor and attend two AA meetings weekly per probation officer’s instructions.
- Young argued the sentence was procedurally unreasonable because the court did not adequately explain exceeding the Guidelines’ policy-statement range.
- Young also argued the sentence was substantively unreasonable because it relied on an erroneous finding that he violated release conditions by not following AA instructions.
- The panel reviewed the procedural challenge for plain error (Young’s general objection did not preserve the specific procedural claim) and reviewed substantive reasonableness for abuse of discretion (that claim was preserved).
Issues
| Issue | Plaintiff's Argument (Young) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether district court procedurally erred by failing to explain a sentence above the Guidelines policy range | Court failed to give adequate reasons for exceeding Guidelines’ policy-statement range | Any explanatory deficiency did not meet plain-error standards | Reviewed for plain error; even if error occurred, Young failed to show it affected substantial rights or the integrity of proceedings; no relief granted |
| Whether sentence was substantively unreasonable because it relied on an erroneous finding of violation (failure to follow AA instructions) | Sentence improperly based on erroneous violation finding (AA sponsor/meetings) | Even if finding was error, it was not the dominant factor in sentencing | No abuse of discretion; error (if any) was not a dominant factor; sentence affirmed |
Key Cases Cited
- United States v. Kippers, 685 F.3d 491 (5th Cir. 2012) (preservation rules and plain-error review for sentencing objections)
- Puckett v. United States, 556 U.S. 129 (2009) (plain-error test elements and remedial discretion)
- United States v. Whitelaw, 580 F.3d 256 (5th Cir. 2009) (requirement that district court provide some explanation when imposing revocation sentence outside Guidelines’ policy range)
- United States v. Reyes, 300 F.3d 555 (5th Cir. 2002) (defendant bears burden to establish plain-error prongs)
- United States v. Warren, 720 F.3d 321 (5th Cir. 2013) (abuse-of-discretion review of substantive reasonableness on revocation)
- United States v. Rivera, 784 F.3d 1012 (5th Cir. 2015) (error occurs only if an impermissible consideration was the dominant factor in revocation sentence)
- United States v. Franklin, 838 F.3d 564 (5th Cir. 2016) (limitations on revocation findings tied to program-compliance conditions)