United States v. Craig Burns
691 F. App'x 288
| 8th Cir. | 2017Background
- Craig Burns was convicted in 2001 of unlawful manufacture of a firearm, conspiracy against rights, and interstate transportation of a stolen vehicle; his supervised release term began October 16, 2014.
- Burns’ supervised-release conditions had been modified at two prior hearings (July 27, 2015 and May 12, 2016).
- At a July 28, 2016 revocation hearing the court considered multiple alleged violations: threats, failure to maintain employment, disobeying directives, being out of place, making false statements, threatening a co‑worker, and refusing to sign in for mental‑health treatment.
- The district court revoked supervised release and sentenced Burns to 12 months’ imprisonment followed by one year supervised release (Guidelines range: 8–14 months).
- Burns appealed, arguing (1) procedural error because the court failed to articulate specific § 3553(a) reasons for imprisonment, and (2) the 12‑month term was substantively unreasonable given his alleged brain injury and primarily technical violations.
- The Eighth Circuit reviewed for abuse of discretion (fact findings for clear error) and affirmed the revocation and sentence.
Issues
| Issue | Burns' Argument | Court/Government Argument | Held |
|---|---|---|---|
| Procedural adequacy of court’s explanation under § 3553(a) | Court failed to articulate specific § 3553(a) factors and only gave general admonitions | District court discussed underlying offenses, prior noncompliance, current violations, and was aware of § 3553(a); not required to list every factor mechanically | No procedural error; explanation sufficed and could be inferred from record |
| Substantive reasonableness of 12‑month prison term | Sentence was excessive, based on accumulated technical violations and not enough weight given to Burns’ brain injury/mental‑health issues | Court considered pervasive, habitual violations and Burns’ failure to take responsibility; medical mitigation limited by Burns’ refusal to release records | Sentence within Guidelines (8–14 months) entitled to presumption of reasonableness; affirmed |
| Burden/standard for revocation | Implied: violations were technical and insufficient to support revocation | Government: revocation proper if violations shown by preponderance; district court has discretion among sanctions | Violations supported by record by preponderance; revocation decision not an abuse of discretion |
Key Cases Cited
- United States v. Petersen, 848 F.3d 1153 (8th Cir.) (standard of review for supervised‑release revocation)
- United States v. Boyd, 792 F.3d 916 (8th Cir.) (preponderance standard for proving violations)
- United States v. White, 840 F.3d 550 (8th Cir.) (review of procedural and substantive reasonableness on revocation)
- United States v. Petreikis, 551 F.3d 822 (8th Cir.) (no mechanical requirement to list every § 3553(a) factor)
- United States v. White Face, 383 F.3d 733 (8th Cir.) (sentencing explanation principles on revocation)
- United States v. Franklin, 397 F.3d 604 (8th Cir.) (awareness of § 3553(a) factors can be inferred from record)
- United States v. Valure, 835 F.3d 789 (8th Cir.) (Guidelines sentence presumption of reasonableness)
- United States v. Robinson, 516 F.3d 716 (8th Cir.) (same principle on Guidelines presumption)
- United States v. Melton, 666 F.3d 513 (8th Cir.) (habitual release violations support revocation)