United States v. Nathaniel Houle, Jr., 20-4238

Houle was a mid-level drug dealer who sold heroin/fentanyl mixtures to a confidential informant on three occasions while on state probation.
One sale occurred immediately after a meeting with his probation officer for a drug test; a third sale occurred at his home with his two-year-old daughter present (child played with a marijuana bag).
Federal agents later searched Houle’s home and found ammunition, cash, suspected cutting agents, marijuana, and digital scales—items consistent with distribution.
Houle pleaded guilty to drug-trafficking charges. The district court calculated a Guidelines range of 70–87 months and sentenced him to 80 months’ imprisonment and five years’ supervised release.
Houle appealed, arguing his sentence was substantively unreasonable under 18 U.S.C. § 3553(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was substantively unreasonable	Houle: district court failed to adequately account for his history/character and should have imposed a lower sentence	Gov./district court: court considered history and characteristics; sentence within Guidelines and justified by offense seriousness and deterrence	Affirmed — within-Guidelines sentence presumed reasonable; Houle failed to rebut presumption
Whether disparity with a co-defendant warranted a lower sentence	Houle: co-defendant with same Guidelines range got 60 months, so Houle’s 80 months is disparate	Gov.: co-defendant dealt cocaine for a shorter time; § 3553(a) does not mandate matching co-defendant sentences	Affirmed — disparity argument insufficient; sentencing courts not required to equalize co-defendant sentences
Whether an alternative lesser sentence would satisfy § 3553(a)	Houle: a 70-month term and three years supervised release would suffice	Gov.: district court weighed § 3553(a) factors and rejected alternatives; appellate court should not reweigh	Affirmed — appellate court will not substitute its own balancing for the district court’s discretion

United States v. Nixon, 664 F.3d 624 (6th Cir. 2011) (abuse-of-discretion standard for substantive-reasonableness review)
United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc) (within-Guidelines sentence carries a presumption of reasonableness; no need to explain rejection of specific alternatives)
United States v. Simmons, 501 F.3d 620 (6th Cir. 2007) (§ 3553(a) does not require courts to equalize sentences among co-defendants)
United States v. Ely, 468 F.3d 399 (6th Cir. 2006) (appellate courts will not reweigh § 3553(a) factors or impose their own preferred sentence)