United States v. Joseph Williams, 998 F.3d 538

Defendant Joseph Williams pleaded guilty to distributing, receiving, and possessing child pornography (three-count information) without a plea agreement.
Williams possessed a massive collection (≈3,000 videos, ≈5,000 images), an instructional manual on grooming/abuse, secretly photographed children, and used a youth-focused social app to groom and exploit minors; he participated in porn-trading chat groups and bragged about/attempted to teach others his methods.
The district court adopted the presentence report, calculated a Guidelines imprisonment range of 210–262 months, and imposed 160 months’ imprisonment (concurrent on counts) plus a 20-year term of supervised release.
The district court explained the §3553(a) sentencing factors when imposing imprisonment but did not separately articulate the reasons for the supervised-release term.
Williams appealed only the supervised-release term, arguing (1) procedural error for lack of a separate explanation and (2) substantive unreasonableness of a 20-year term following 160 months’ imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court procedurally erred by not separately explaining the 20-year supervised-release term	Williams: court failed to state reasons for supervised release separately	Gov: district court’s §3553(a) discussion for imprisonment sufficed; no statute or precedent requires repeat explanation	No error; separate explanation not required unless retribution was the principal basis for the overall sentence
Whether the 20-year supervised-release term is substantively unreasonable	Williams: 20 years is excessive after 160 months and unsupported by the record	Gov: defendant’s conduct (collection, grooming, photos, chat groups, attempts to exploit minors) shows ongoing risk to children, justifying lengthy supervision	Not substantively unreasonable; 20 years justified to protect children

United States v. Villafuerte, 502 F.3d 204 (2d Cir. 2007) (plain-error standard for unpreserved sentencing objections)
United States v. Rosa, 957 F.3d 113 (2d Cir. 2020) (district court must adequately explain chosen sentence)
United States v. Molina, 356 F.3d 269 (2d Cir. 2004) (purposes of §3553(c) statement include appellate review and informing public/parties)
United States v. Cavera, 550 F.3d 180 (2d Cir. 2008) (appellate review considers whether reasons can bear the weight assigned under totality of circumstances)
United States v. Alvarado, 720 F.3d 153 (2d Cir. 2013) (no additional explanation required where court considered §3553(a) and adequately explained sentence)
Johnson v. United States, 529 U.S. 53 (2000) (supervised release serves rehabilitative ends distinct from incarceration)
Tapia v. United States, 564 U.S. 319 (2011) (retribution cannot be considered when imposing supervised release)
United States v. Burden, 860 F.3d 45 (2d Cir. 2017) (district courts often give one explanation for entire sentence; separate reasoning advisable when incarceration is principally justified by retribution)
United States v. Jenkins, 854 F.3d 181 (2d Cir. 2017) (example where lengthy supervised release was found problematic when record lacked contact/attempted contact with minors)
United States v. Rigas, 583 F.3d 108 (2d Cir. 2009) (standards for substantive unreasonableness review)