United States v. Dione Taylor, 688 F. App'x 181

Dione Aliquan Taylor pled guilty to being a felon in possession of a firearm (18 U.S.C. §§ 922(g)(1), 924(a)(2)).
The district court sentenced Taylor to 120 months’ imprisonment.
Counsel filed an Anders brief, stating no meritorious appeal issues but questioning whether the sentence was unreasonable under 18 U.S.C. § 3553(a).
The Fourth Circuit reviews sentences for procedural and substantive reasonableness under an abuse-of-discretion standard.
The district court: correctly calculated the Guidelines range, permitted argument, considered § 3553(a) factors, and explained the sentence (seriousness of offense and criminal history).
The Fourth Circuit concluded Taylor’s within-Guidelines sentence was presumptively reasonable and not rebutted on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Taylor’s 120-month sentence is procedurally reasonable	Taylor argued the sentence may be unreasonable under § 3553(a) considerations	Government argued the district court properly calculated Guidelines, heard arguments, and explained the sentence	Procedurally reasonable — court properly calculated Guidelines, allowed argument, and explained its reasoning
Whether Taylor’s sentence is substantively reasonable	Taylor suggested the sentence may be excessive given § 3553(a) factors	Government maintained a within-Guidelines sentence is presumptively reasonable and justified by offense seriousness and history	Substantively reasonable — presumption not rebutted; sentence affirmed

Anders v. California, 386 U.S. 738 (1967) (procedure for counsel to seek withdrawal when appeal is frivolous)
Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review; procedural and substantive reasonableness standards)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (within-Guidelines sentences are presumptively reasonable)