United States v. Johnathan Hall, 702 F. App'x 157

Johnathan Olandus Hall pled guilty to being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)).
The PSR incorporated the Government’s written Factual Basis, which described the arresting officer seeing a muzzle flash from a handgun in Hall’s hand and a victim with a serious gunshot wound; Hall did not dispute the Factual Basis except for irrelevant facts.
The PSR applied a cross-reference for assault with intent to murder based on the shooting; Hall initially objected but later withdrew that objection and accepted the Guidelines calculation.
At sentencing Hall sought a downward variance on multiple grounds (mental health, alleged overstatement of criminal history, disparity) and, for the first time at the initial hearing, claimed someone else shot the victim.
Sentencing proceeded over three hearings; the court allowed discovery on a recorded statement allegedly incriminating another shooter (in defense counsel’s possession) but Hall never introduced the tape.
The district court imposed a 110-month sentence (bottom of the 110–120 month Guidelines range). Hall appealed, arguing the court procedurally erred by failing to address his claim that he was not the shooter.

Issue	Hall's Argument	Government's Argument	Held
Whether the district court procedurally erred by not explicitly addressing Hall’s claim that he was not the shooter when rejecting a downward variance	The court failed to consider and explain rejection of his nonfrivolous claim that someone else fired the shot, which could warrant a lower sentence	The record shows the court considered the claim (multiple hearings, offered opportunity to introduce tape, noted factual basis/no second gun, eyewitness testimony) so no separate explicit statement was required	No procedural error; the court considered and rejected Hall’s claim based on the record and Hall’s choice not to introduce the recording

United States v. Helton, 782 F.3d 148 (4th Cir. 2015) (district court need not mechanically recite § 3553(a) factors)
United States v. Lynn, 592 F.3d 572 (4th Cir. 2010) (sentencing court must justify sentence and rejection of arguments based on § 3553)
United States v. Carter, 564 F.3d 325 (4th Cir. 2009) (district judge should address nonfrivolous arguments for a different sentence)
Rita v. United States, 551 U.S. 338 (2007) (court must have a reasoned basis and provide sufficient explanation to permit meaningful review)
Gall v. United States, 552 U.S. 38 (2007) (sentencing explanation promotes perception of fairness and enables review)
United States v. Montes-Pineda, 445 F.3d 375 (4th Cir. 2006) (context of the record can supply sufficient content to evaluate consideration of § 3553(a) factors)