United States v. David Worley
2012 U.S. App. LEXIS 14387
4th Cir.2012Background
- Worley pleaded guilty to four charges in December 2010 related to methamphetamine offenses.
- district court denied a requested variance but sentenced Worley to 100 months with three years of supervised release; co-defendant Reedy received 57 months.
- The district court imposed fifteen special conditions for supervised release under a standing order for sex-offense convictions, including restrictions on contact with children and housing restrictions.
- Worley’s past included a decade-old state sex-offense conviction; at sentencing the district court relied on that history to apply tier II sex-offender conditions.
- Worley objected to drug-quantity calculations, the inclusion of a psychological report, and later challenges to the special conditions as overly restrictive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether conditions 1, 6, and 14 were properly justified | Worley | Worley | Reversed for those conditions; lack of current danger evidence requires reversal |
| Whether remaining conditions beyond 1, 6, 14 were properly related to §3553(a) factors | Worley was not shown to need broader restrictions based on old convictions | Court could impose broader conditions to further rehabilitation and protect the public | Vacated and remanded for district court to reconsider in light of this opinion |
| Whether the 100-month sentence was procedurally and substantively reasonable | Worley argued rehabilitation and mitigating factors were not adequately considered | District court properly weighed §3553(a) factors and evidence; sentence within guidelines is presumptively reasonable | Sentence affirmed as procedurally and substantively reasonable |
Key Cases Cited
- United States v. Davis, 452 F.3d 991 (8th Cir. 2006) (plain-error review for restrictive conditions when no current threat shown)
- United States v. Armel, 585 F.3d 182 (4th Cir. 2009) (need for adequate explanation of conditions under §3583(d))
- Pepper v. United States, 131 S. Ct. 1229 (2011) (rehabilitation evidence may be highly relevant post-sentencing under §3661)
- United States v. Moreland, 437 F.3d 424 (4th Cir. 2006) (no mandated checklist; must show reasoned basis for factors)
- Rita v. United States, 551 U.S. 338 (2007) (judge must provide reasoned basis showing consideration of arguments)
- United States v. Abu Ali, 528 F.3d 210 (4th Cir. 2008) (district court must tailor explanation to defendant and record)
- United States v. Voelker, 489 F.3d 139 (3d Cir. 2007) (caution in imposing parental-contact restrictions absent current threat)