United States v. Charles Lamar Thomas, 682 F. App'x 874

In 2011 Thomas pleaded guilty to failing to register as a sex offender under 18 U.S.C. § 2250(a); PSR showed he moved from Wisconsin to Georgia in 2008 and never updated registration.
For that conviction he received 7 months’ imprisonment (concurrent with a state sentence) and 10 years of supervised release with SORNA and a 72-hour residence-notification condition.
In 2014 his probation officer filed a revocation petition alleging, among other things, that Thomas moved counties without notifying authorities and failed to notify probation within 72 hours. He later pleaded guilty to a related Georgia offense and served 2 years in state custody.
At the federal revocation hearing Thomas admitted the violations, offered mitigating facts (eviction, homelessness attempt, health issues), and the government sought imprisonment plus an additional 10 years of supervised release.
The district court revoked supervised release, imposed 12 months’ imprisonment (consecutive to state time), and ordered 10 more years of supervised release. Thomas appealed the substantive reasonableness of the 10-year term.

Issue	Thomas’s Argument	Government’s Argument	Held
Whether the additional 10-year supervised-release term is substantively unreasonable	The 10-year term is excessive given mitigating circumstances (eviction/homelessness, health problems, and ongoing state supervision)	The sentence is appropriate to deter, protect the public, and address Thomas’s repeated noncompliance	Affirmed — term is substantively reasonable
Whether the district court properly considered § 3553(a) factors on revocation	Court failed to weigh mitigating factors sufficiently	Court considered § 3553(a) and Thomas’s record justified long supervision	Affirmed — district court adequately considered § 3553(a) and exercised discretion
Whether the sentence is unreasonable because it approaches statutory maximum	10 years is disproportionate relative to circumstances	10 years is well below the statutory maximum (life) for SORNA violation and thus reasonable	Affirmed — sentence below statutory maximum supports reasonableness
Whether reliance on Thomas’s criminal history was an abuse of discretion	Court overemphasized past conduct	Defendant’s extensive history of parole revocations and registration noncompliance supports long-term supervision	Affirmed — weighting of factors was within discretion

Velasquez Velasquez, 524 F.3d 1248 (11th Cir. 2008) (standard of review for supervised-release revocation sentences)
Sarras, 575 F.3d 1191 (11th Cir. 2009) (burden on challenger to show sentence unreasonable)
Gall v. United States, 552 U.S. 38 (2007) (review for substantive reasonableness under totality of circumstances)
Gonzalez, 550 F.3d 1319 (11th Cir. 2008) (district court need not recite every § 3553(a) factor; sentence well below statutory max supports reasonableness)
Clay, 483 F.3d 739 (11th Cir. 2007) (weight of § 3553(a) factors entrusted to district court)
Irey, 612 F.3d 1160 (11th Cir. 2010) (abuse of discretion where court fails to consider or misweights significant factors)
Crisp, 454 F.3d 1285 (11th Cir. 2006) (overreliance on one § 3553(a) factor can signal unreasonableness)