United States v. Ladarrius Walker
705 F. App'x 192
| 4th Cir. | 2017Background
- Defendant Ladarrius O’Brian Walker pled guilty to possession of a firearm by a felon.
- District court calculated an advisory Sentencing Guidelines range of 63–78 months.
- The district court imposed an above-Guidelines variance sentence of 90 months.
- Walker appealed, arguing the variance sentence was substantively unreasonable.
- The Fourth Circuit reviewed for abuse of discretion and considered procedural and substantive reasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 90-month variance sentence was substantively unreasonable | Walker: variance was greater than justified by § 3553(a) factors | Government: district court adequately explained reasons and did not rely on improper factors | Affirmed — sentence substantively reasonable; district court did not abuse discretion |
Key Cases Cited
- United States v. Lymas, 781 F.3d 106 (4th Cir. 2015) (district court must make individualized assessment and adequately explain reasons for a variance)
- Gall v. United States, 552 U.S. 38 (2007) (reasonableness review and deference to district court; consider extent of variance)
- United States v. Bolton, 858 F.3d 905 (4th Cir. 2017) (vacatur appropriate where district court’s stated reasoning for variance is inadequate or relies on improper factors)