United States v. Jose Zavala-Garcia, 689 F. App'x 222

Defendant Jose Antonio Zavala-Garcia pled guilty to one count of illegal reentry after a felony conviction in violation of 8 U.S.C. § 1326.
District court sentenced him to 8 months’ imprisonment and 3 years’ supervised release.
Defense counsel filed an Anders brief asserting no meritorious appeal but asking the court to consider whether the supervised-release term was procedurally reasonable.
Zavala-Garcia declined to file a pro se supplemental brief; the Government did not file an appellate brief.
The district court relied on U.S.S.G. § 5D1.1(c) and considered the 18 U.S.C. § 3553(a) factors, citing the need for deterrence and public protection.
The Fourth Circuit reviewed for procedural and substantive reasonableness and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the imposition of supervised release was procedurally reasonable	Zavala-Garcia (via Anders submission) questioned whether supervised release was properly imposed and explained	District court (and Government) relied on U.S.S.G. § 5D1.1(c) and § 3553(a), citing deterrence and public protection	Affirmed: court found no procedural error and upheld supervised release as reasonable

Anders v. California, 386 U.S. 738 (1967) (framework for counsel to withdraw when appeal lacks merit)
Gall v. United States, 552 U.S. 38 (2007) (standards for procedural and substantive reasonableness of sentences)
United States v. Howard, 773 F.3d 519 (4th Cir. 2014) (review standard for sentencing procedural and substantive reasonableness)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of substantive reasonableness for Guideline-range sentences)