United States v. Julius Lamont Smoot, 700 F. App'x 293

Julius Lamont Smoot pleaded guilty to possession of a firearm by a convicted felon and was sentenced to 34 months' imprisonment.
Counsel on appeal filed an Anders brief asserting no meritorious issues but questioning sentence reasonableness; Smoot and the Government did not file briefs.
The Fourth Circuit reviewed the record and the Anders brief and considered whether the sentence was procedurally and substantively reasonable.
The district court calculated the Guidelines range without objection and engaged in a detailed discussion of the presentence report and Smoot’s criminal history at sentencing.
The district court imposed a within-Guidelines sentence and provided a brief on-the-record explanation; the sentencing hearing as a whole showed consideration of § 3553(a) factors.
The Fourth Circuit found no procedural error, declined to find the within-Guidelines sentence unreasonable, and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was procedurally reasonable	Smoot (via Anders) questioned the reasonableness of the sentence but raised no specific procedural objections	The Government: district court correctly calculated Guidelines and considered PSR and § 3553(a) factors	Court: No procedural error — district court properly calculated range and sufficiently considered factors
Whether the sentence was substantively reasonable	Smoot argued the within-Guidelines sentence might be unreasonable	The Government argued the within-Guidelines sentence is presumptively reasonable and justified by record	Court: Within-Guidelines sentence presumed reasonable; Smoot did not rebut presumption, so sentence is substantively reasonable
Adequacy of district court’s explanation for sentence	Smoot implied that brief explanation might be insufficient	The Government pointed to the detailed colloquy and PSR discussion at sentencing	Court: Although final statement was brief, the full hearing and questioning showed adequate explanation
Whether any meritorious appellate issues exist under Anders	Appellate counsel found none meritorious aside from sentence question	Government did not assert meritorious issues	Court: After full review, no meritorious issues; Anders procedures satisfied; affirmance appropriate

Anders v. California, 386 U.S. 738 (1967) (procedures for withdrawal when counsel believes appeal is frivolous)
Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing procedural and substantive reasonableness of sentences)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption that within-Guidelines sentence is reasonable)