United States v. DeWayne Bradley, 713 F. App'x 850

Bradley was previously convicted in 2008 for attempted possession with intent to distribute cocaine and was serving a term of supervised release when he participated in a new cocaine trafficking conspiracy from Nov. 2015 to July 2016.
He was indicted and pled guilty to conspiracy to possess with intent to distribute cocaine; that conviction formed the basis for revoking his supervised release on the 2008 case.
At original sentencing Bradley had criminal-history category I; his new conviction qualified as a Grade A supervised-release violation under the Guidelines.
The Chapter 7 Guidelines range for a Grade A violation with history category I is 12–18 months; the district court imposed a 24-month sentence (an upward variance).
Bradley appealed, arguing (1) the Guidelines range was miscalculated and (2) the upward variance was procedurally and substantively unreasonable for failing to adequately explain reliance on § 3553(a) factors.
The Eleventh Circuit affirmed, holding the Guidelines calculation (12–18 months) was correct and the upward variance was procedurally and substantively reasonable based on the court’s consideration of Bradley’s history, offense circumstances, and need for deterrence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court miscalculated the advisory Guidelines range for revocation	Bradley: his applicable range was not properly calculated	Government: Bradley’s new conviction was a Grade A violation and with CHC I the range is 12–18 months	Held: No error — range properly calculated as 12–18 months under U.S.S.G. § 7B1.4(a) and related provisions
Whether the 24-month revocation sentence was procedurally unreasonable for failing to consider § 3553(a) factors	Bradley: court failed to ensure proper Guidelines calculation and failed to adequately explain upward variance	Government: court expressly considered history, offense, need for deterrence, and Guidelines	Held: Procedurally reasonable — record shows consideration of relevant § 3553(a) factors
Whether the 24-month sentence was substantively unreasonable (abuse of discretion)	Bradley: upward variance was excessive given Guidelines range	Government: district court permissibly weighed § 3553(a) factors and could assign great weight to deterrence/history	Held: Substantively reasonable — no clear error of judgment in weighing factors
Whether the sentence was an improper Guidelines "departure" under § 4A1.3 rather than a variance	Bradley: characterized the sentence as an upward departure under § 4A1.3	Government: district court relied on § 3553(a) factors and never cited departure provisions	Held: It was an upward variance based on § 3553(a), not a Guidelines departure

Gall v. United States, 552 U.S. 38 (2007) (framework for reviewing reasonableness of sentences)
United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014) (standard for reviewing revocation sentences)
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) (abuse-of-discretion standard and when a district court errs in weighing § 3553(a) factors)
United States v. Pridgeon, 853 F.3d 1192 (11th Cir. 2017) (controlled-substance offenses count as Grade A violations for supervised-release purposes)
United States v. Clay, 483 F.3d 739 (11th Cir. 2007) (district court may accord great weight to particular § 3553(a) factors)
Irizarry v. United States, 553 U.S. 708 (2008) (distinguishing Guidelines "departures" from non-Guidelines variances under § 3553(a))