United States v. Steven Singletary
685 F. App'x 290
4th Cir.2017Background
- Steven L. Singletary pled guilty in 1997 to being a felon in possession of a firearm under 18 U.S.C. §§ 922(g), 924(e).
- After Johnson v. United States, Singletary successfully moved under 28 U.S.C. § 2255 and the district court vacated his life sentence because he was no longer an Armed Career Criminal.
- On resentencing the district court imposed a 120-month federal term and ordered it to run consecutive to an undischarged state sentence for related conduct.
- Singletary appealed, arguing the 120-month sentence was greater than necessary under 18 U.S.C. § 3553(a) and should have run concurrently with his state sentence pursuant to U.S.S.G. § 5G1.3(b)(2).
- The Fourth Circuit reviewed the sentence for reasonableness under an abuse-of-discretion standard and noted Singletary conceded no procedural error in the district court’s sentencing.
- The Fourth Circuit affirmed, finding the district court adequately considered the § 3553(a) factors and permissibly exercised its discretion to impose a consecutive federal sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal sentence must run concurrent to an undischarged state sentence when the state offense involves related conduct | Singletary: Guidelines §5G1.3(b)(2) supports a concurrent sentence; consecutive term is greater than necessary under §3553(a) | Gov’t: Guidelines are advisory; district court may impose consecutive sentence after considering §3553(a) factors | Court: No requirement to run concurrent; district court properly considered §3553(a) and did not abuse discretion |
| Whether the 120-month sentence was substantively unreasonable | Singletary: Consecutive 120 months exceeds what is necessary to satisfy §3553(a) | Gov’t: District court weighed factors and justified the sentence as reasonable | Court: Sentence is substantively reasonable; affirmed |
Key Cases Cited
- United States v. McCoy, 804 F.3d 349 (4th Cir. 2015) (sets out deferential abuse-of-discretion standard for reviewing sentences)
- United States v. King, 673 F.3d 274 (4th Cir. 2012) (confirms reasonableness review of sentences inside and outside Guidelines range)
- Gall v. United States, 552 U.S. 38 (2007) (requires consideration of procedural and substantive reasonableness under §3553(a))
- United States v. Carter, 564 F.3d 325 (4th Cir. 2009) (district court must show it considered parties’ arguments and provide reasoned basis for its decision)
- United States v. Nania, 724 F.3d 824 (7th Cir. 2013) (explains §5G1.3(b) is advisory and courts are not required to impose concurrent sentences)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (held the ACCA residual clause void for vagueness, leading to vacatur of some enhanced sentences)