United States v. Jose Martinez Santelices, 698 F. App'x 605

Defendant Jose Martinez de Santelices admitted violations of his supervised release and faced a revocation hearing.
The district court revoked supervised release and imposed an 18-month prison term, to run consecutively to a separate pending sentence.
The Sentencing Guidelines range for the revocation was 12–18 months.
Martinez appealed, arguing the district court failed to adequately explain its chosen sentence in violation of 18 U.S.C. § 3553(c)(1).
The Eleventh Circuit reviewed de novo whether the court complied with § 3553(c)(1) and whether the sentence was legally proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court failed to state adequate reasons for a within-Guidelines revocation sentence under 18 U.S.C. § 3553(c)(1)	Martinez: court did not adequately explain the basis for the 18-month sentence	Government/District Court: case was simple, court considered § 3553(a) factors and parties’ arguments and stated reasons, including defendant’s pending underlying case	Court affirmed: explanation was sufficient; in a conceptually simple case with a within-Guidelines (12–18 mo) range, extensive explanation not required and § 3553(c)(1) did not mandate additional detail

United States v. Aimufa, 122 F.3d 1376 (11th Cir.) (reviews legality of sentences imposed on supervised-release revocation de novo)
United States v. Bonilla, 463 F.3d 1176 (11th Cir. 2006) (§ 3553(c)(1) compliance reviewed de novo even without objection)
United States v. Williams, 438 F.3d 1272 (11th Cir. 2006) (review focuses on court’s actions at sentencing)
Rita v. United States, 551 U.S. 338 (2007) (in conceptually simple cases, limited explanation suffices; judge may rely on Guidelines’ reasoning)
United States v. Veteto, 920 F.2d 823 (11th Cir. 1991) (failure to comply with § 3553(c)(1) renders sentence unlawful)