United States v. Craig Sanders, 511 F. App'x 463

Sanders pleaded guilty to a felony for false distress by Coast Guard, after a prank cost $53,306.16 in search efforts.
District court imposed 2.5 years’ imprisonment, 3 years’ supervised release with mandatory substance-abuse program and possible testing, $100 assessment, and restitution to the Coast Guard.
Sanders’ counsel did not object to any sentencing aspects at the time of sentencing.
The district court applied a four-level enhancement for a hoax causing substantial disruption under U.S.S.G. § 2A6.1(b)(4).
The court asked for further objections post-sentencing; Sanders’ counsel stated he had nothing to add.
Appeal relies on plain-error review (except for substantive reasonableness), alleging ineffective assistance, improper enhancement, improper delegation, and unreasonable sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the four-level enhancement proper?	Sanders	Sanders	Enhancement upheld
Did the district court improperly delegate testing decisions to the Probation Department?	Sanders	Sanders	No improper delegation
Was the sentencing procedurally reasonable under plain-error review?	Sanders	Sanders	Procedural consideration satisfied
Is the sentence substantively reasonable under abuse-of-discretion review?	Sanders	Sanders	Within acceptable discretion; affirmed

United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (plain-error framework and forfeiture considerations)
United States v. Bostic, 371 F.3d 865 (6th Cir. 2004) (requirement to object to sentencing; final speaking opportunity)
United States v. Freeman, 640 F.3d 180 (6th Cir. 2011) (need for meaningful sentencing hearing; special objections)
United States v. Sypher, 684 F.3d 622 (6th Cir. 2012) (ineffective-assistance claims generally not raised on direct appeal)
United States v. Gunter, 620 F.3d 642 (6th Cir. 2010) (meaningful sentencing and consideration of arguments)
United States v. Vowell, 516 F.3d 503 (6th Cir. 2008) (standard for substantive reasonableness review)