United States v. Joshua Vidal, 2013 U.S. App. LEXIS 2137

Vidal, a Two-Six gang member, joined a plan to rob a cocaine stash house with an undercover FBI officer.
He led the operation, assembled four coconspirators, and claimed prior successful robberies to the undercover agent.
He pleaded guilty to four counts: conspiracy and attempt to possess with intent to distribute five kilograms or more of cocaine, Hobbs Act robbery attempt, and firearm in furtherance of a drug trafficking crime.
PSR calculated offense level 35, leadership enhancement, and a 3-point acceptance of responsibility, yielding an advisory 210–262 month range on counts I–III; 60 months mandatory on count IV.
Mentally ill history was noted: Vidal had bipolar disorder and depression; Dr. Pearlson evaluated him and diagnosed PTSD, bipolar spectrum disorder, claustrophobia, and substance abuse.
District court adopted PSR, imposed concurrent 210 months on counts I–III and 60 months on count IV, with minimal discussion of Vidal’s mental-health mitigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court adequately considered Vidal's psychiatric mitigation	Vidal's mental-health mitigation required explicit consideration.	Court acknowledged mental-health issues but did not need extensive explanation.	Remanded for reconsideration; vacated and sentence to be reconsidered with proper analysis.

Rita v. United States, 551 U.S. 338 (U.S. 2007) (requires explanation when mitigation is presented)
Miranda, 505 F.3d 785 (7th Cir. 2007) (remand where mental-illness argument not addressed)
Schroeder, 536 F.3d 746 (7th Cir. 2008) (discussed adequacy of sentencing rationale)
Cunningham, 429 F.3d 673 (3d Cir. 2005) (court must respond to colorable mitigation arguments)
Begin, 696 F.3d 405 (7th Cir. 2012) (acknowledgment of mitigation argument required)
Robertson, 662 F.3d 871 (7th Cir. 2011) (need to address principal mitigation arguments)
Villegas-Miranda, 579 F.3d 798 (7th Cir. 2009) (remand when court's discussion is too cursory)