United States v. Latrell Coe, 992 F.3d 594

In July 2019 Latrell Coe (age 18) and two accomplices robbed a Verizon store in Mt. Carmel, Illinois at gunpoint, stealing over $25,000 in cash and merchandise.
Police arrested the trio; Coe pleaded guilty to Hobbs Act robbery (18 U.S.C. § 1951) and brandishing a firearm during a crime of violence (18 U.S.C. § 924(c)).
The PSR included juvenile adjudications and other arrests; the Guidelines range produced a total term of 117–125 months (84 months consecutive mandatory on § 924(c)).
Defense sought a downward variance to 84 months+1 day, arguing Coe’s youth/brain immaturity and harms of father incarceration; defense submitted articles and a letter but offered only generalized mitigation at sentencing.
The district judge imposed 117 months (bottom of the Guidelines), explaining reliance on the violent nature of the offense, emotional impact on victims, tactical vest/forethought, Coe’s juvenile history, and deterrence; the judge addressed the youth and absent-father arguments and gave them limited weight.
On appeal Coe argued the judge impermissibly considered race (racial stereotyping about absent fathers) and procedurally erred by insufficiently addressing the brain-development mitigation; the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Impermissible consideration of race at sentencing	Judge relied on racial stereotype about absent Black fathers to deny mitigation	Judge’s remarks were race-neutral, tied to Coe’s actual family support and individual circumstances	Affirmed — judge’s comment, read in context, was not reliance on race and did not affect sentence
Failure to adequately consider "brain science" mitigation	Judge failed to give a reasoned basis for rejecting youth/brain-development mitigation for an 18‑year‑old	Court properly acknowledged age and brain-development literature; argument was a generic "stock" claim and insufficient to outweigh violent conduct and history	Affirmed — judge considered and reasonably discounted the argument; no procedural error

United States v. Bustos, 912 F.3d 1059 (7th Cir. 2019) (de novo review for procedural sentencing challenges)
United States v. Sunmola, 887 F.3d 830 (7th Cir. 2018) (standard for constitutional sentencing review)
United States v. Grisanti, 943 F.3d 1044 (7th Cir. 2019) (equal protection context in sentencing)
United States v. Walton, 907 F.3d 548 (7th Cir. 2018) (due-process claim based on inaccurate information at sentencing)
United States v. Vargas, 915 F.3d 417 (7th Cir. 2019) (sequencing nonconstitutional and constitutional claims)
United States v. Patel, 921 F.3d 663 (7th Cir. 2019) (off-topic judicial remarks require showing they affected the sentence)
United States v. Smith, 562 F.3d 866 (7th Cir. 2009) (upholding sentence where questionable remark did not affect court’s reasoning)
United States v. Graham, 915 F.3d 456 (7th Cir. 2019) (mitigating "stock arguments" need less individualized discussion)
United States v. Martinez, 520 F.3d 749 (7th Cir. 2008) (same on stock mitigating arguments)