United States v. Morris
709 F. App'x 54
| 2d Cir. | 2017Background
- Defendant Tyquan Morris pleaded guilty to being a felon in possession of ammunition in SDNY.
- Sentencing guideline range stipulated by parties: 57–71 months; district court imposed statutory maximum of 10 years.
- District court emphasized Morris fired multiple shots on a populated city sidewalk and noted the high risk of death or serious harm.
- Court also relied on Morris’s recent completion (within a year) of a sentence for a violent drug conspiracy to assess high risk of recidivism.
- Morris raised procedural and substantive unreasonableness challenges to the sentence on appeal; he did not contest his conviction.
Issues
| Issue | Plaintiff's Argument (Gov) | Defendant's Argument (Morris) | Held |
|---|---|---|---|
| Procedural reasonableness: adequacy of district court's explanation | Court provided sufficient explanation for a lengthy sentence and considered §3553(a) factors | District court failed to explain why maximum sentence was necessary and did not properly weigh mitigating factors | Affirmed — court gave adequate, detailed reasons (danger to community + recidivism) and noted mitigation was considered |
| Substantive reasonableness: whether 10-year sentence was within permissible range | Sentence justified by extraordinarily dangerous conduct and recent violent criminal history | Sentence excessive given no injury, acceptance of responsibility, employment, support letters, and troubled childhood | Affirmed — sentence within range of permissible decisions given conduct and recidivism risk |
| Preservation/plain-error standard | Government contends plain-error review may apply because issue not preserved | Morris argued on appeal the explanation was insufficient | Court reviewed under abuse-of-discretion standard and found no error |
| Weight assigned to sentencing factors | District court may weigh danger to public and recidivism heavily when justified | Morris argued undue emphasis on violent conduct over mitigating circumstances | Affirmed — weight given to those factors was permissible |
Key Cases Cited
- United States v. Cavera, 550 F.3d 180 (2d Cir. 2008) (standard of review and reasonableness framework for sentencing)
- United States v. Sindima, 488 F.3d 81 (2d Cir. 2007) (district courts must adequately explain sentences above guideline range)
- United States v. Rattoballi, 452 F.3d 127 (2d Cir. 2006) (explanation required to allow review of sentence rationale)
- Kimbrough v. United States, 552 U.S. 85 (2007) (district court discretion in sentencing considerations)
- United States v. Aldeen, 792 F.3d 247 (2d Cir. 2015) (more robust justification required when imposing sentence substantially above guidelines)
- United States v. Rigas, 490 F.3d 208 (2d Cir. 2007) (limits on overturning district court’s substantive sentencing determinations)