United States v. Darius Benson, 24-4489

Darius Keyon Benson pled guilty in 2018 to firearm possession after felony and domestic violence misdemeanor convictions, with no written plea agreement.
He was initially sentenced as an armed career criminal to 180 months in prison and five years of supervised release.
On direct appeal, his conviction and sentence were affirmed; however, a later § 2255 motion was granted, finding he no longer qualified as an armed career criminal.
At resentencing, Benson's Guidelines range was found to be 21 to 27 months, but he was sentenced to time served and two years of supervised release.
Benson's counsel filed an Anders brief, raising the procedural and substantive reasonableness of his new sentence and the term of supervised release.
The district court’s amended judgment was affirmed by the Fourth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural & substantive reasonableness of time-served sentence	Sentence constituted an unexplained upward variance from the new Guidelines range.	Sentence was reasonable given excess time served and factors considered.	Any error is harmless; sentence affirmed.
Reasonableness of two-year term of supervised release	Term is unreasonable and not adequately justified.	Supervision necessary for transition and within Guidelines/statute.	Two-year term is reasonable and affirmed.

Gall v. United States, 552 U.S. 38 (Sentencing decisions reviewed for abuse of discretion; procedural and substantive reasonableness standard applied)
United States v. Johnson, 529 U.S. 53 (Excess prison time does not offset supervised release; supervised release serves rehabilitative goals)