United States v. Elijah Grant
671 F. App'x 171
| 4th Cir. | 2016Background
- Elijah Grant admitted violating conditions of his supervised release at a revocation hearing.
- The district court revoked supervised release and sentenced Grant to 12 months' imprisonment.
- The statutory maximum for revocation was three years under 18 U.S.C. § 3583(e)(3).
- Grant’s counsel filed an Anders brief challenging reasonableness of the sentence but concluding no meritorious appeal issues; Grant filed no pro se brief.
- The district court considered the Chapter Seven policy statement range (6–12 months) and relevant § 3553(a) factors, emphasizing Grant’s persistent drug use in justifying the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the revocation sentence is within statutory limits | N/A (appeal challenges reasonableness) | Sentence is within three-year statutory maximum | Yes — within statutory maximum |
| Whether the revocation sentence is procedurally reasonable | Grant argues potential unreasonableness (via counsel) | District court considered policy range and § 3553(a) factors | Procedurally reasonable |
| Whether the revocation sentence is substantively reasonable | Appellate counsel questions reasonableness | Court provided individualized basis (persistent drug use) for sentence | Substantively reasonable |
| Whether the sentence is plainly unreasonable under Circuit precedent | Counsel raised issue under Anders but found no meritorious claim | Court applied Webb/Crudup/Thompson framework and upheld sentence | Not plainly unreasonable; affirmed |
Key Cases Cited
- United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (standard for reviewing revocation sentences: within statutory maximum and not plainly unreasonable)
- United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (procedural and substantive reasonableness framework for revocation sentences)
- United States v. Thompson, 595 F.3d 544 (4th Cir. 2010) (first determine unreasonableness before assessing "plain" unreasonableness; statement-of-reasons requirement)
- United States v. Moulden, 478 F.3d 652 (4th Cir. 2007) (revocation sentencing requires a statement of reasons, though less detailed than post-conviction sentencing)
- Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for appointed counsel filing a brief asserting no meritorious grounds for appeal)