United States v. Curtis Martin, Jr., 676 F. App'x 214

Defendant Curtis R. Martin, Jr. pled guilty to wire fraud in violation of 18 U.S.C. §§ 2(b), 1343.
District court calculated an advisory Guidelines range of 63–78 months.
The court imposed a 96‑month prison sentence, a significant upward variance from the Guidelines range.
Martin appealed, arguing the sentence was unreasonable.
The Fourth Circuit reviewed for abuse of discretion under 18 U.S.C. § 3553(a) and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural reasonableness of variance	Martin argued the district court misapplied facts and failed to justify upward variance	Government defended the court’s factual findings and § 3553(a) analysis	Court found no procedural error; district court made individualized assessment and adequately explained reasons
Factual findings (start date of fraud)	Martin contended the court erred in dating the scheme	Government supported the court’s timeline	Court affirmed the court’s finding as not procedurally erroneous
Comparisons to other crimes (e.g., drug crimes)	Martin challenged the court’s analogy/comparison to drug offenses	Government argued comparisons were within court’s discretion for context	Court held the comparison did not create procedural error
Substantive reasonableness of 96‑month sentence	Martin argued the variance was greater than justified by § 3553(a) factors	Government argued the court reasonably weighed § 3553(a) and justified the extent of the variance	Court concluded the sentence was substantively reasonable and deferred to district court’s judgment

United States v. Lymas, 781 F.3d 106 (4th Cir. 2015) (standard for reviewing reasonableness and need for individualized § 3553(a) explanation)
Gall v. United States, 552 U.S. 38 (2007) (abuse‑of‑discretion review of sentencing; review steps for procedural and substantive reasonableness)
United States v. Diosdado‑Star, 630 F.3d 359 (4th Cir. 2011) (deference to district court’s § 3553(a) determinations)