United States v. Stephen Lee Hamlin
687 F. App'x 862
| 11th Cir. | 2017Background
- Stephen Hamlin appealed an 18-month prison sentence imposed after the district court revoked his supervised release.
- The Sentencing Guidelines recommended 8–14 months; the district court imposed 18 months (an upward variance) and no additional supervised-release term.
- District court explained the variance by finding Hamlin unamenable to supervision, noting repeated supervised-release violations and Hamlin’s failure to appear at a reset sentencing hearing.
- At an earlier hearing the court had warned Hamlin that further violations could lead to a harsher sentence and had reset sentencing to give him an opportunity to comply.
- Hamlin argued the district court failed to adequately explain the sentence/its upward variance and that the sentence was substantively unreasonable.
- The Eleventh Circuit affirmed, holding the court provided sufficient reasons for the upward variance and that the sentence was substantively reasonable.
Issues
| Issue | Plaintiff's Argument (Hamlin) | Defendant's Argument (Government / District Court) | Held |
|---|---|---|---|
| Adequacy of explanation for upward variance under 18 U.S.C. § 3553(c)(2) | Court failed to state specific reasons for imposing a sentence above the guideline range. | Court explicitly found Hamlin unamenable to supervision, cited repeated violations and failure to appear, and explained why increased prison time (no further supervision) was appropriate. | Affirmed — district court gave sufficient, specific reasons for upward variance. |
| Procedural reasonableness under § 3553(a) (plain-error review) | Court did not adequately explain sentence under § 3553(a). | Court had previously warned Hamlin and reset sentencing to give him a chance, making lengthy repetition unnecessary; explanation was adequate. | No plain error — explanation was adequate given circumstances. |
| Substantive reasonableness of 18-month sentence | Sentence is greater than necessary and unreasonable given Hamlin’s rehabilitative efforts. | Sentence was justified by Hamlin’s repeated noncompliance, failure to appear, and lack of amenability to supervision; court reasonably prioritized public protection and deterrence. | Affirmed — sentence was substantively reasonable. |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (2007) (standard for reviewing procedural and substantive reasonableness of sentences)
- United States v. Livesay, 525 F.3d 1081 (11th Cir. 2008) (requirement that district court adequately explain chosen sentence)
- United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014) (plain-error review for unpreserved procedural objections)
- United States v. Parks, 823 F.3d 990 (11th Cir. 2016) (de novo review for § 3553(c)(2) arguments)
- United States v. Langston, 590 F.3d 1226 (11th Cir. 2009) (standard for substantive-reasonableness review)
- United States v. Williams, 526 F.3d 1312 (11th Cir. 2008) (district court discretion in weighting § 3553(a) factors)
- United States v. Sarras, 575 F.3d 1191 (11th Cir. 2009) (burden on challenger to show sentence unreasonable)