United States v. Irvin Edwards
678 F. App'x 120
| 4th Cir. | 2017Background
- Edwards appeals a district court judgment revoking his supervised release and imposing nine months’ imprisonment plus four years’ supervised release.
- Counsel filed an Anders brief stating no meritorious issues, but challenging whether the sentence was unreasonable and whether reasons for additional supervised release were explained.
- Edwards did not file a pro se supplemental brief; the proceeding is presented in an unpublished per curiam opinion not binding precedent.
- The court reviews revocation sentences for reasonableness, within the statutory maximum, applying a two-step inquiry.
- The within-range sentence is presumed reasonable under the policy-statement framework; the court considers whether a proper basis supports the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Edwards' revocation sentence reasonable? | Edwards argues the sentence is unreasonable. | District Court contends the sentence is within range and reasonably justified. | Yes; sentence not unreasonable. |
| Did the district court adequately explain the additional supervised-release term? | Edwards contends explanation for extra supervised release is needed. | Court provided a proper basis for the additional term. | Yes; explanation deemed reasonable. |
Key Cases Cited
- United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (broad discretion in supervising-release revocation and standard of plain unreasonableness)
- United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (proper basis required for sentence up to statutory maximum; policy-statement range presumptively reasonable)
- United States v. Thompson, 595 F.3d 544 (4th Cir. 2010) (reviewing whether revocation sentence is unreasonable by first assessing reasonableness)