United States v. Harris, 843 F.3d 311

Marcus Harris committed three armed robberies in Jan–Feb 2013 (two in Indiana, one in Illinois); arrested and charged in Indiana state court for one Indiana robbery.
While in state custody he received a federal target letter for the Illinois (Addison) robbery and was appointed a federal public defender.
The federal public defender failed to update Harris or his state counsel about federal proceedings before Harris pled guilty and was sentenced in Indiana state court.
Harris was later federally indicted for the Illinois robbery, pled guilty, and stipulated that the uncharged Indiana robbery was relevant conduct.
At federal sentencing the parties proposed a hypothetical Guidelines grouping (treating the Indiana conviction as if charged federally) to compensate for the public defender’s failure; the district court instead treated the state conviction as prior criminal history, calculated a slightly higher Guidelines range, imposed a below-Guidelines sentence of 196 months reduced by 36 months credit and ordered it concurrent with the state sentence (resulting in 160 months).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred procedurally by rejecting the parties' agreed hypothetical Guidelines calculation without adopting or explaining rejection	Harris: court failed to accept or explain rejection of the hypothetical grouped Guidelines that would compensate for federal counsel’s error	Government: court addressed the argument, correctly treated the state conviction as prior history under the Guidelines, and gave Harris requested consideration	Court: No error — district court acknowledged the hypothetical, explained why actual state conviction meant it need not adopt the hypothetical, and gave an adequate explanation and lenient below-Guidelines sentence
Whether the court failed to follow Garcia‑Segura by not asking if defense was satisfied the court addressed principal arguments	Harris: court did not make the specific Garcia‑Segura inquiry after sentencing	Government: court asked parties if anything was omitted and gave Harris chance to respond; any omission was harmless	Court: No error — inquiry substituted by asking if anything was omitted, Harris responded and thus had opportunity to be heard; any technical omission harmless

United States v. Howard, 729 F.3d 655 (7th Cir.) (standard for sufficiency of sentencing explanation)
United States v. Spiller, 732 F.3d 767 (7th Cir.) (district must adequately explain sentencing choice)
United States v. Schlueter, 634 F.3d 965 (7th Cir.) (requirement to explain sentencing decisions)
United States v. Gary, 613 F.3d 706 (7th Cir.) (court must consider and explain treatment of arguments raising unusual circumstances)
United States v. Garcia‑Segura, 717 F.3d 566 (7th Cir.) (encouraging courts to ask post‑sentence whether defense’s principal arguments were addressed)
United States v. Cruz, 787 F.3d 849 (7th Cir.) (waiver of arguments when counsel confirms all arguments addressed)