United States v. Rashallah Parham, 24-4205

Rashallah Lamick Parham pled guilty to being a felon in possession of a firearm and was sentenced to 46 months' imprisonment.
In the same proceeding, Parham’s supervised release for a prior conviction was revoked, and he received an additional consecutive 24-month sentence.
Parham’s attorney filed an Anders brief, indicating no meritorious grounds for appeal but raising three issues for review.
Parham did not file a supplemental pro se brief, and the government declined to file a brief.
The appellate court reviewed the arguments and affirmed both the criminal and revocation sentences imposed by the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of § 922(g)(1) under Second Amendment	Law changed by Rahimi makes § 922(g)(1) facially unconstitutional	Binding precedent supports constitutionality	§ 922(g)(1) is facially constitutional per circuit precedent
Unreasonableness of Total Sentence	Sentence failed to fully consider young age at prior offenses & mental health	Sentence was reasonable, factors considered	Sentence was procedurally and substantively reasonable
Ineffective Assistance of Counsel	Counsel failed to raise mental health as mitigation	Not addressed	Not cognizable on direct appeal; must be raised in § 2255

United States v. Olano, 507 U.S. 725 (plain error review standard)
Gall v. United States, 552 U.S. 38 (reasonableness review for sentences)
United States v. Nance, 957 F.3d 204 (procedural reasonableness analysis)
United States v. Louthian, 756 F.3d 295 (presumption of reasonableness for within-Guidelines sentences)
United States v. Patterson, 957 F.3d 426 (broad discretion in revocation sentences)
United States v. Freeman, 24 F.4th 320 (standard for ineffective assistance claims on direct appeal)
United States v. Faulls, 821 F.3d 502 (ineffective assistance should not be raised on direct appeal)