United States v. Hill
683 F. App'x 3
| 1st Cir. | 2017Background
- Adam Hill pled guilty to possession with intent to distribute heroin and cocaine in Sanford, Maine, in violation of 21 U.S.C. § 841(a)(1).
- District court calculated a Guidelines sentencing range (GSR) of 84–105 months and imposed a sentence at the bottom of the range: 84 months.
- Hill appealed, arguing (1) procedural error for allegedly failing to consider 18 U.S.C. § 3553(a) factors and (2) that the 84-month sentence was substantively unreasonable.
- The Government defended the sentence; Hill did not dispute the GSR calculation on appeal.
- The First Circuit reviewed for plain error on the procedural claim (unpreserved below) and for abuse of discretion on substantive reasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court failed to consider 18 U.S.C. § 3553(a) factors | (Gov.) Court properly considered § 3553(a) factors | (Hill) Court did not appropriately consider/weigh § 3553(a) factors | Court found no procedural error; record shows careful consideration of aggravating and mitigating factors |
| Whether the 84-month within-Guidelines sentence was substantively unreasonable | (Gov.) Sentence is reasonable given offense and history | (Hill) Sentence is substantively unreasonable | Affirmed: sentence was supported by a plausible rationale and defensible result |
Key Cases Cited
- United States v. Martin, 520 F.3d 87 (1st Cir. 2008) (framework for procedural and substantive sentencing review)
- United States v. Duarte, 246 F.3d 56 (1st Cir. 2001) (plain-error standard for unpreserved sentencing claims)
- United States v. Flores-Machicote, 706 F.3d 16 (1st Cir. 2013) (sentencing court has broad discretion to weigh § 3553(a) factors)
- United States v. Dixon, 449 F.3d 194 (1st Cir. 2006) (no requirement to address each § 3553(a) factor in rote sequence)
- United States v. Bermúdez-Meléndez, 827 F.3d 160 (1st Cir. 2016) (qualitative weight assigned to factors is for sentencing court)
- United States v. Clogston, 662 F.3d 588 (1st Cir. 2011) (appellate court generally should not second-guess reasoned sentencing judgments)
- United States v. Ruiz-Huertas, 792 F.3d 223 (1st Cir. 2015) (standard of review for substantive reasonableness)
- United States v. Pelletier, 469 F.3d 194 (1st Cir. 2006) (heavy burden to show a within-Guidelines sentence is substantively unreasonable)
- United States v. Trinidad-Acosta, 773 F.3d 298 (1st Cir. 2014) (burden is heavier when sentence is below the GSR)