United States v. Gerald Wright, 662 F. App'x 476

Gerald Wright was convicted in 2004 of conspiring to manufacture/distribute ≥50g methamphetamine after a prior felony drug conviction; sentenced to 101 months imprisonment and 8 years supervised release.
Wright began supervised release in July 2011 and accumulated multiple violations (open-container citation; refusal to participate in required treatment seven times; missed monthly reports three times; failure to complete court-ordered community service; two weekend confinement terms).
In 2015 Wright provided a diluted urine sample and subsequently had multiple presumptive positive marijuana tests and admissions of recent use.
The district court noted extensive criminal history, mental-health and substance-abuse issues, prior leniency, and services offered; classified the violations as Grade C under the Guidelines.
With criminal-history category III, the advisory Guidelines range for revocation was 5–11 months; the district court imposed ten months imprisonment and two years of supervised release.
Wright appealed, arguing the court failed to consider all 18 U.S.C. § 3553(a) factors and imposed an unreasonable sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court failed to consider all applicable § 3553(a) factors before revoking supervised release and imposing ten months’ imprisonment	Wright: court did not fully and carefully consider mitigating § 3553(a) factors and thus sentenced unreasonably	Government: court expressly stated it considered applicable § 3553(a) factors, Wright’s history, treatment efforts, and prior leniency; sentence is within advisory Guidelines and presumptively reasonable	Affirmed: court considered relevant factors; not required to make findings on each factor; within-Guidelines sentence presumed reasonable and not rebutted

United States v. Carothers, 337 F.3d 1017 (8th Cir. 2003) (standard of review for supervised-release revocation)
United States v. Growden, 663 F.3d 982 (8th Cir. 2011) (abuse-of-discretion framework for unreasonable sentences)
United States v. Kreitinger, 576 F.3d 500 (8th Cir. 2009) (abuse-of-discretion explained)
United States v. Scales, 735 F.3d 1048 (8th Cir. 2013) (within-Guidelines sentence presumptively reasonable)
United States v. Goodale, 738 F.3d 917 (8th Cir. 2013) (defendant bears burden to rebut presumption of reasonableness)
United States v. Fry, 792 F.3d 884 (8th Cir. 2015) (district court not required to make specific findings on each § 3553(a) factor)
United States v. Deegan, 605 F.3d 625 (8th Cir. 2010) (same principle regarding § 3553(a) findings)
United States v. Keating, 579 F.3d 891 (8th Cir. 2009) (presumption that court considered factors presented by counsel)
United States v. Ruelas-Mendez, 556 F.3d 655 (8th Cir. 2009) (court may weigh some § 3553(a) factors more heavily)
United States v. Hum, 766 F.3d 925 (8th Cir. 2014) (escalating sanctions for repeated supervised-release violations supports deterrence)
Gall v. United States, 552 U.S. 38 (2007) (presumption of reasonableness for within-Guidelines sentences)