United States v. Matthew Thomas, 24-5063

Matthew Thomas, a federal prisoner, was sentenced to 114 months for possession of a firearm by a convicted felon (18 U.S.C. § 922(g)(1)).
The sentence was about 45% above the high end of the advisory guidelines range (63-78 months) after the district court found inapplicable the Armed Career Criminal Act (ACCA) enhancement originally sought.
Thomas had an extensive criminal history, including three sexual assault convictions (one involving a minor), repeated violent offenses, and prior substantial sentences that did not deter further criminal conduct.
At sentencing, the court considered Thomas’s mental health and substance abuse issues but concluded that these did not outweigh his violent recidivism and the need to protect the public.
Thomas appealed the sentence, challenging only the substantive reasonableness of the upward variance as an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substantive reasonableness of	Sentence overly relies on criminal	Upward variance justified by	District court did not
upward variance from guidelines	history; fails to give weight to	violent recidivism and lack of	abuse its discretion;
	mitigating mental health factors	deterrent effect of prior sentences	sentence affirmed

Gall v. United States, 552 U.S. 38 (2007) (articulates abuse-of-discretion standard for reviewing sentencing decisions)
United States v. Mitchell, 107 F.4th 534 (6th Cir. 2024) (addresses substantive reasonableness of sentencing)
United States v. Parrish, 915 F.3d 1043 (6th Cir. 2019) (describes weighing of sentencing factors and appellate review)