United States v. Ivory Charles Brinson, 693 F. App'x 858

Brinson had supervised release revoked after testing positive for marijuana.
District court imposed a new term of supervised release: life, less 14 months.
Brinson argued the sentence was procedurally unreasonable because the court relied on his prior commutation instead of the 18 U.S.C. § 3553(a) factors.
He also argued the new term was substantively unreasonable as an improper sentence balancing.
The Eleventh Circuit reviews revocation sentences for abuse of discretion, using a two-step procedural/substantive reasonableness framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural reasonableness of life supervised-release term	Brinson: court impermissibly relied on his commutation and failed to consider § 3553(a) factors	Government: court considered parties' arguments and statutory factors; commutation was one relevant fact among many	Affirmed — court considered § 3553(a) and the record shows reasons; no procedural error
Substantive reasonableness of the term	Brinson: sentence is substantively unreasonable and overly reliant on one factor	Government: sentence reasonably weighed recidivism risk and criminal history	Affirmed — no abuse of discretion; court permissibly gave significant weight to criminal history and recidivism risk

United States v. Trailer, 827 F.3d 933 (11th Cir. 2016) (standard and two-step review for supervised-release revocation sentences)
Rita v. United States, 551 U.S. 338 (2007) (district court must give enough explanation to show consideration of arguments)
United States v. Dorman, 488 F.3d 936 (11th Cir. 2007) (failure to state consideration of § 3553(a) factors is not fatal if record shows consideration)
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (substantive-reasonableness abuse of discretion standards)