United States v. Jordan Koskinen, 20-2268

Koskinen pleaded guilty in 2016 to conspiracy to manufacture methamphetamine and was sentenced to 37 months' imprisonment and 3 years' supervised release.
After release in May 2019, he admitted to possessing and using methamphetamine and the court revoked supervised release, imposing 12 months + 1 day and another 3 years of supervised release.
Shortly after his second release, Koskinen was discharged from a residential treatment program for continued substance use and refusal to participate; he was booked into Chippewa County Jail where suboxone strips taped in his waistband were found.
Probation filed a petition alleging four supervised-release violations (failure to participate in treatment, leaving the district, failing to report law-enforcement contact, bringing contraband into the jail); Koskinen admitted three violations and disputed the contraband charge, claiming a prescription.
The district court found all four violations proved by a preponderance of the evidence, imposed a 15-month prison sentence (one month above the Guidelines) and no further supervised release, citing repeated violations, failed treatment, deterrence, and that supervision had not worked.
Koskinen appealed, arguing the upward variance was substantively unreasonable because the court overemphasized the suboxone possession and failed to account for his need for treatment.

Issue	Koskinen's Argument	Government/District Court Argument	Held
Whether the 15-month sentence (1 month above Guidelines) is substantively unreasonable	Court arbitrarily added 1 month and over-weighted the suboxone possession given his prescription and inadvertence	Variance justified by repeated, proximate supervised-release violations and failed attempts at treatment; one-month variance is modest	Affirmed: sentence not substantively unreasonable; district court did not abuse its discretion
Whether the court improperly failed to consider Koskinen's need for substance-abuse treatment	Court ignored need for medical/substance-abuse care when increasing sentence	Court considered treatment history and concluded prior supervised release and residential care failed, so custody was necessary for punishment and deterrence	Affirmed: court adequately considered treatment needs and § 3553(a) factors
Whether the district court adequately explained the upward variance and applied proper review standard	Explanation was insufficient for deviating from Guidelines	Court provided adequate reasons (repeated violations, resistance to treatment); standard of review is deferential abuse-of-discretion	Affirmed: explanation sufficient; appellate deference applies

United States v. Gall, 552 U.S. 38 (sets standard for sentencing reasonableness review)
United States v. Bolds, 511 F.3d 568 (6th Cir.) (applies abuse-of-discretion review to supervised-release revocation sentences)
Holguin-Hernandez v. United States, 140 S. Ct. 762 (addresses "greater than necessary" standard under § 3553(a))
United States v. Solano-Rosales, 781 F.3d 345 (6th Cir.) (plain-error review for unraised procedural sentencing challenges)
United States v. Kirby, 418 F.3d 621 (6th Cir.) (upholding above-Guidelines sentence where defendant repeatedly violated supervised release)
United States v. Small, 988 F.3d 241 (6th Cir.) (discusses procedural vs. substantive sentencing challenges)