United States v. Joseph Alfred, 684 F. App'x 350

Defendant Joseph Junior Alfred appealed a 57-month sentence for attempted bank robbery under 18 U.S.C. § 2113(a).
Alfred argued the district court committed procedural error by failing to adequately explain its reasons for imposing a within-Guidelines sentence and rejecting his request for a shorter sentence.
The Fourth Circuit reviews sentences for reasonableness under an abuse-of-discretion standard and will reverse only for non-harmless error.
The district court noted concern that Alfred was likely to recidivate and imposed special supervised-release conditions.
The Court of Appeals found the record showed the district court heard and considered the parties’ arguments and gave a reasoned basis for rejecting a downward variance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court inadequately explained a within-Guidelines sentence	Alfred: court failed to adequately explain reasons and to address his mitigation arguments	Government: court gave sufficient individualized reasons and considered parties' arguments	Affirmed — explanation sufficient; no procedural error
Whether appellate review requires more detailed explanation for within-Guidelines sentence	Alfred: more detail needed to permit meaningful appellate review	Government: within-Guidelines need not be elaborate if reasons are clear	Affirmed — concise explanation acceptable

Gall v. United States, 552 U.S. 38 (sentencing procedure; calculate Guidelines, consider §3553(a), explain sentence)
Rita v. United States, 551 U.S. 338 (judge must show consideration of parties' arguments and reasoned basis)
United States v. Lynn, 592 F.3d 572 (insufficient explanation is significant procedural error)
United States v. Hernandez, 603 F.3d 267 (within-Guidelines explanation need not be lengthy)
United States v. Montes-Pineda, 445 F.3d 375 (sentence explanation must allow effective appellate review)