United States v. Shadarryl Turner
671 F. App'x 41
| 4th Cir. | 2016Background
- Appellant Shadarryl Turner appealed the district court’s revocation of his supervised release and a 24‑month prison sentence.
- The appeal challenges the reasonableness of the revocation sentence.
- The district court calculated the Chapter Seven policy‑statement range, heard counsel’s arguments, and considered the relevant 18 U.S.C. § 3553(a) factors.
- The court provided an explanation for the chosen sentence; its comments included a passing reference to promoting respect for the law.
- The Fourth Circuit reviewed whether the sentence was procedurally or substantively unreasonable and whether it was plainly unreasonable.
- The Fourth Circuit concluded the district court committed no procedural or substantive error and affirmed the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 24‑month revocation sentence was procedurally unreasonable | Turner argued the sentence was unreasonable (implying procedural flaws in sentencing) | Government argued the court followed Chapter Seven, considered § 3553(a), and adequately explained the sentence | Court held sentence was not procedurally unreasonable; proper considerations made and adequate explanation given |
| Whether the 24‑month revocation sentence was substantively unreasonable | Turner argued the sentence was greater than necessary | Government argued the sentence fell within statutory discretion and matched sentencing goals | Court held sentence was substantively reasonable; within court’s broad discretion |
| Whether the sentence was plainly unreasonable on appellate review | Turner urged that, viewed as a whole, the sentence was plainly unreasonable | Government maintained any reference to promoting respect for the law did not render the sentence plainly unreasonable | Court held the passing remark did not make the sentence plainly unreasonable; affirmed |
| Whether the district court adequately applied Chapters Seven and § 3553(a) factors | Turner contended inadequate consideration/explanation | Government showed the record reflected those considerations and counsels’ arguments were addressed | Court held the district court properly calculated the policy range and considered applicable factors |
Key Cases Cited
- United States v. Padgett, 788 F.3d 370 (4th Cir.) (standards for reviewing revocation sentences)
- United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (substantive‑reasonableness framework for revocation sentences)
- United States v. Thompson, 595 F.3d 544 (4th Cir. 2010) (requirements for district court’s statement of reasons on revocation)
- United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (discussion of § 3553(a) factors and revocation sentencing)
