United States v. Henry Steiger, 83 F.4th 932

Steiger pleaded guilty (Sept. 2017) to one count of conspiracy to commit wire fraud and three counts of wire fraud; PSI listed statutory maximum 20 years per count and an initial guideline range of 0–6 months; the district court sentenced him to 3 years’ probation.
While on federal probation, Steiger was convicted in Florida (June 2019) of second-degree murder for facts showing concealment of the victim’s body; the Florida conviction and record formed the basis for the probation-revocation petition.
At the federal revocation hearing, the court found Steiger committed the new crime, revoked probation, and—despite a (revocation-related) guideline range the parties described as substantially lower—imposed 20 years’ imprisonment on each count to run concurrently with the Florida life sentence.
The district court stated it had considered the §3553(a) factors and the record but did not articulate a specific reason on the record for imposing an above-guidelines, near‑statutory‑maximum sentence.
Steiger did not object at sentencing to the sufficiency of the court’s explanation; he appealed arguing the sentence was procedurally and substantively unreasonable and that the court failed to give the specific §3553(c)(2) reason for the upward variance.
The Eleventh Circuit vacated and remanded for resentencing, holding the district court’s explanation was not sufficiently specific under §3553(c)(2) and circuit precedent.

Issue	Steiger’s Argument	Government’s Argument	Held
Whether the district court violated 18 U.S.C. §3553(c)(2) by failing to state a specific reason for imposing an above-guideline sentence	The court gave only general remarks and failed to state a specific, record-based reason for the upward variance	The record and context (heinous murder facts) make the court’s reasoning clear without a lengthy explanation; Rita/Chavez‑Meza allow reliance on the record	The court violated §3553(c)(2); the explanation was not sufficiently specific, so vacatur and remand required (per Elec. Cir. precedent)
Standard of review for an unpreserved §3553(c)(2) challenge	Relief is required even without contemporaneous objection because the record can be silent; §3553(c)(2) errors are reviewable de novo	The court can consult the record and apply ordinary plain-error review; no need for automatic reversal	The court applied de novo review for the §3553(c)(2) claim (following Eleventh Circuit’s Parks), and remanded for resentencing

Gall v. United States, 552 U.S. 38 (explains procedural‑reasonableness and need for adequate explanation of sentence)
Rita v. United States, 551 U.S. 338 (within‑guidelines sentences sometimes require only brief explanation)
Chavez‑Meza v. United States, 138 S. Ct. 1959 (amount of explanation depends on case circumstances; reliance on record can suffice in simple cases)
United States v. Parks, 823 F.3d 990 (11th Cir. 2016) (requires specific reasons for non‑guideline sentence and adopts per‑se reversal rule for §3553(c)(2) errors)
United States v. Bonilla, 463 F.3d 1176 (11th Cir. precedent relied on in Parks regarding §3553(c)(2) omissions)
United States v. Williams, 438 F.3d 1272 (11th Cir. precedent concerning required on‑the‑record statements for departures/variances)
United States v. Booker, 543 U.S. 220 (Sentencing Guidelines are advisory)
United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014) (plain‑error review for unpreserved procedural sentencing challenges)
Puckett v. United States, 556 U.S. 129 (plain‑error standard for unpreserved objections on appeal)
Dominguez‑Benitez v. United States, 542 U.S. 74 (distinguishes structural errors from ordinary errors for review)