United States v. Mario Tiller, 20-2228

Mario Tiller pleaded guilty (Nov. 2019) to three federal counts: being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)), possession with intent to distribute/distribution of cocaine base (21 U.S.C. § 841), and possession of a firearm in furtherance of a drug trafficking crime (18 U.S.C. § 924(c)).
Defense conceded Tiller qualified as a career offender under the Guidelines and as an armed career criminal under 18 U.S.C. § 924(e); he has a lengthy criminal history spanning over two decades.
Tiller suffers from serious mental illness (schizophrenia); a mental health professional found him competent to plead and not in need of hospitalization.
The Sentencing Guidelines range was 262–327 months; the District Court denied a downward departure for diminished capacity but imposed a downward variance to the statutory mandatory minimum of 240 months and recommended prison mental-health treatment.
On appeal Tiller argued that his 20-year sentence violated the Eighth Amendment because of his schizophrenia; he did not raise an Eighth Amendment claim in district court, so the Third Circuit reviewed for plain error and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a 20-year mandatory sentence violates the Eighth Amendment as cruel and unusual because Tiller has schizophrenia	Tiller: schizophrenia makes him categorically less culpable (analogous to juveniles/mentally retarded), so mandatory 20-year term is disproportionate	Government: sentence is statutory/mandatory, within permissible range, Tiller failed to preserve an Eighth Amendment claim, and he offered no evidence that all schizophrenics are less culpable	Affirmed. Under plain-error review, no plain error; Tiller failed to show a gross imbalance or provide evidence entitling him to relief

Miller v. Alabama, 567 U.S. 460 (2012) (holding mandatory life without parole for juveniles unconstitutional)
Atkins v. Virginia, 536 U.S. 304 (2002) (holding death penalty unconstitutional for intellectually disabled defendants)
Ewing v. California, 538 U.S. 11 (2003) (discussing Eighth Amendment proportionality and deference to legislative sentencing choices)
United States v. Burnett, 773 F.3d 122 (3d Cir. 2014) (articulating the "narrow proportionality principle" and the "gross imbalance" gateway for noncapital sentences)
United States v. Olano, 507 U.S. 725 (1993) (governing plain-error review)