United States v. Jackie Williams
16-15078
| 11th Cir. | Nov 28, 2017Background
- Defendant Jackie Williams pleaded guilty to one count of wire fraud under 18 U.S.C. § 1343.
- The Sentencing Guidelines range was 33–41 months. The district court imposed a 70-month sentence (an upward variance).
- Williams appealed, arguing the sentence was procedurally and substantively unreasonable.
- Procedural challenge: Williams argued the district court failed to give a sufficiently compelling justification for the upward variance.
- Substantive challenge: Williams argued the court relied improperly on deterrence alone under 18 U.S.C. § 3553(a).
- The Eleventh Circuit reviewed for abuse of discretion and evaluated both procedural and substantive reasonableness under Gall.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural reasonableness of upward variance | Sentence procedurally unreasonable because court did not give sufficiently compelling justification for variance | District court adequately explained seriousness, victims' losses, and deterrence—sufficient justification | Affirmed: court provided a reasoned basis and sufficiently compelling reasons for the degree of variance |
| Substantive reasonableness; reliance on deterrence | Sentence substantively unreasonable because court improperly relied only on deterrence | Court considered deterrence plus seriousness, need to protect public, victims' losses, and restitution concerns | Affirmed: sentence substantively reasonable; court permissibly weighed deterrence among other § 3553(a) factors |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (2007) (establishes two-step reasonableness review and standard for variance explanation)
- Rita v. United States, 551 U.S. 338 (2007) (district court need not provide extensive detail but must show a reasoned basis for sentencing)
- United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) (sentencing explanation need not be exhaustive)
- United States v. Tome, 611 F.3d 1371 (11th Cir. 2010) (burden on challenger to show sentence unreasonable)
- United States v. Barrington, 648 F.3d 1178 (11th Cir. 2011) (district court has discretion over weight given to § 3553(a) factors)