United States v. Stanley Aubrey Baker
712 F. App'x 903
| 11th Cir. | 2017Background
- In 2016 Baker pled guilty to possession with intent to distribute cocaine (Class C felony); sentenced to 14 months imprisonment and 3 years supervised release.
- Baker’s supervised release began Feb 3, 2017 in the Southern District of Mississippi; within weeks a petition alleged multiple violations: failure to notify change of residence, leaving the district without permission, burglary of a dating partner’s home, and possession of a Ruger 9mm pistol and ammunition.
- Baker was arrested in Houston on Feb 18, 2017 and found with the pistol; at the revocation hearing the Marshal and the burglary victim testified and the court found Baker violated his supervision.
- The government recommended the statutory maximum term upon revocation (24 months); Baker argued he had not been charged criminally for the alleged conduct.
- The district court imposed 24 months’ imprisonment (the statutory maximum for revocation following a Class C felony) and 12 months’ additional supervised release, explaining the guideline provisions for supervised-release violations were not appropriate and Baker had shown he could not comply with supervision.
- Baker appealed, contending the sentence was procedurally and substantively unreasonable; the Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural reasonableness: Did the district court adequately explain the revocation sentence and consider § 3553(a)? | Gov't: revocation mandatory for firearm possession under § 3583(g); explanation and record suffice. | Baker: district court failed to explain the sentence and failed to consider § 3553(a) factors. | Court: No procedural error—§ 3583(g) mandatory revocation applies, court heard arguments, referenced relevant facts, and gave a reasoned basis for 24 months. |
| Substantive reasonableness: Was 24 months excessive given the circumstances? | Gov't: sentence warranted by nature of violations, Baker’s history, and deterrence. | Baker: sentence substantively unreasonable given mitigating facts (e.g., remorse, lack of criminal charges). | Court: Sentence substantively reasonable—district court permissibly weighed factors and emphasized Baker’s inability to comply with supervision. |
Key Cases Cited
- United States v. Brown, 224 F.3d 1237 (11th Cir. 2000) (mandatory revocation under § 3583(g) for firearm possession does not require § 3553(a) consideration)
- United States v. Sweeting, 437 F.3d 1105 (11th Cir. 2006) (reasonableness standard for supervised-release revocation sentences)
- Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review for sentencing reasonableness)
- Rita v. United States, 551 U.S. 338 (2007) (district court should state enough to show consideration of parties’ arguments and a reasoned basis)
- United States v. Cubero, 754 F.3d 888 (11th Cir. 2014) (procedural errors in sentencing review standard)
- United States v. Dorman, 488 F.3d 936 (11th Cir. 2007) (record showing consideration of § 3553(a) factors can suffice)