United States v. Laron Dimitric Player, 676 F. App'x 837

Background

Loran Player’s supervised release was revoked after he was found to have driven a vehicle alleged to be stolen; the district court found a violation under 18 U.S.C. § 3583(e)(3) and imposed a 24‑month prison term.
Evidence: multiple items belonging to Player were found in the vehicle and Player (and his wife) could not identify the person they said they borrowed the car from or provide basic details about him.
At the revocation hearing the government added a Receiving Stolen Property charge; the new Guidelines range (as provided by the government) became 21–27 months.
Player admitted to three prior violations; the district court found by a preponderance of the evidence that Player knew or had reasonable grounds to know the vehicle was stolen.
The district court sentenced Player to 24 months (mid‑Guidelines) and did not explicitly renew an earlier 14‑month offer after electing to hold a hearing on the stolen‑property allegation.
On appeal Player argued (1) the court erred in finding knowledge of the vehicle’s stolen status and (2) the 24‑month sentence was an abuse of discretion; the Eleventh Circuit affirmed.

Issues

Issue	Plaintiff's Argument (Player)	Defendant's Argument (Government/District Court)	Held
Whether district court erred in finding by a preponderance that Player knew or had reasonable grounds to know the vehicle was stolen	Player: evidence insufficient; he said he borrowed the car for a doctor’s appointment and lacked knowledge it was stolen	Government: items belonging to Player in the car, inability to identify lender, credibility determinations support finding of knowledge	Court: No error — credibility findings and preponderance standard support the conclusion that Player knew or should have known the car was stolen
Whether the 24‑month sentence was an abuse of discretion or procedurally flawed (failure to renew/offer 14‑month deal)	Player: court should have renewed the 14‑month offer or imposed 14 months; the later sentence was substantively unreasonable	Government: Player consented to a hearing that made the earlier offer unavailable; court considered Guidelines and § 3553(a) factors and sentenced within the new range	Court: No abuse of discretion; record shows consideration of Guidelines and § 3553(a), sentence within range and below statutory maximum, so sentence is reasonable

Key Cases Cited

United States v. Gregg, 179 F.3d 1312 (11th Cir. 1999) (deference to district court credibility findings)
United States v. Copeland, 20 F.3d 412 (11th Cir. 1994) (standard of review for supervised‑release revocation)
Gall v. United States, 552 U.S. 38 (2007) (procedural and substantive reasonableness review of sentencing)
United States v. Tome, 611 F.3d 1371 (11th Cir. 2010) (burden on challenger to show sentence unreasonable)
United States v. Campbell, 473 F.3d 1345 (11th Cir. 2007) (requirements for record to permit review when parties not given post‑sentence objection opportunity)
United States v. Dorman, 488 F.3d 936 (11th Cir. 2007) (no need for explicit § 3553(a) recitation if record shows consideration)
United States v. Hunt, 526 F.3d 739 (11th Cir. 2008) (within‑Guidelines sentences ordinarily reasonable)
United States v. Gonzalez, 550 F.3d 1319 (11th Cir. 2008) (sentence below statutory maximum can indicate reasonableness)
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (significant Guidelines deviations require justification)
United States v. Turner, 474 F.3d 1265 (11th Cir. 2007) (plain‑error review when no timely objection)
United States v. Jones, 899 F.2d 1097 (11th Cir. 1990) (district court must give parties opportunity to object after sentencing)
Mabry v. Johnson, 467 U.S. 504 (1984) (no constitutional right to enforcement of plea offers)
Puckett v. United States, 556 U.S. 129 (2009) (discussion of plea offer enforcement principles)
United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (effect of stipulations on appellate review)