United States v. Skip Watson
20-4474
| 4th Cir. | Jul 1, 2021Background:
- Appellant Skip Watson pled guilty to conspiracy to defraud the United States (18 U.S.C. § 371).
- District court imposed 41 months’ imprisonment and $33,860.35 restitution.
- Appellate counsel submitted an Anders brief stating no meritorious issues but questioning whether the district court adequately explained the sentence.
- Watson received notice of appeal rights but filed no pro se supplemental brief.
- The Fourth Circuit reviewed the sentence for procedural and substantive reasonableness under Gall and found the court properly calculated the Guidelines, considered § 3553(a) factors, and adequately explained the sentence.
- Court affirmed; counsel must notify Watson of right to petition the Supreme Court and may move to withdraw if a meritsless certiorari petition is requested.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of district court's explanation for the sentence (procedural reasonableness) | Watson: court failed to adequately explain basis for sentence | Gov't: court properly calculated Guidelines, applied §3553(a), and explained reasons | Court: no procedural error; explanation adequate; sentence procedurally reasonable |
| Substantive reasonableness of within-Guidelines sentence | Watson: sentence unreasonable on the merits | Gov't: within-Guidelines sentence is presumptively reasonable and presumption not rebutted | Court: presumption stands; Watson did not overcome it; sentence substantively reasonable |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (2007) (framework for procedural and substantive reasonableness review of sentences)
- Anders v. California, 386 U.S. 738 (1967) (requires counsel to file brief and notify defendant when no meritorious appeal exists)
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (within-Guidelines sentences are presumptively reasonable)