United States v. Spencer Fitzpatrick, 943 F.3d 838

Fitzpatrick sold 26.6 grams of methamphetamine to a confidential informant; officers seized an additional 26.22 grams and arrested him.
PSR: base offense level 30; criminal-history category VI (28 points); career-offender enhancement raised level to 37 then, after acceptance, total offense level 34 → advisory Guidelines range 262–327 months.
Fitzpatrick requested a downward variance based on a severely abusive and unstable childhood (physical/verbal abuse, abandonment at age 6, 17 group homes, later exposure to a drug-using biological father).
The district court acknowledged the upbringing but found Fitzpatrick’s extensive, recent criminal conduct (including firing a gun into an occupied residence and immediate recidivism after release from a long sentence) diminished the mitigating weight of his childhood.
The court applied an agreed 15% downward departure from the bottom of the Guidelines range (starting point 262 months) and sentenced Fitzpatrick to 223 months’ imprisonment.
Fitzpatrick appealed, arguing the sentence was substantively unreasonable because the district court improperly discounted his childhood by relying on his age; the Eighth Circuit reviews such sentences for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s denial of a downward variance (for difficult upbringing) rendered the sentence substantively unreasonable	Fitzpatrick: court improperly used his age to discount childhood trauma and thus erred in denying a variance	Government: court properly considered §3553(a) factors, reasonably weighed severe criminal history and public-safety concerns; age is a permissible consideration in assigning weight to childhood mitigation	Affirmed: no abuse of discretion; district court considered the relevant factors, reasonably weighed them, and permissibly declined the requested variance

United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (en banc) (abuse-of-discretion standard for sentencing review)
United States v. Williams, 624 F.3d 889 (8th Cir. 2010) (defines categories of abuse of discretion in sentencing)
Gall v. United States, 552 U.S. 38 (2007) (court must consider totality of circumstances and extent of any variance)
United States v. Wahlstrom, 588 F.3d 538 (8th Cir. 2009) (evaluate substantive reasonableness with reference to §3553(a))
United States v. Callaway, 762 F.3d 754 (8th Cir. 2014) (district courts may weigh sentencing factors unequally)
United States v. Holdsworth, 830 F.3d 779 (8th Cir. 2016) (denial not reversible simply because court gave less weight than defendant desired)
United States v. Ruelas-Mendez, 556 F.3d 655 (8th Cir. 2009) (upholding denial of variance on similar facts)