United States v. Sultana Siddiqui, 688 F. App'x 230

Sultana Siddiqui pleaded guilty to conspiracy to commit mail and wire fraud under 18 U.S.C. § 1349 and was sentenced to 24 months imprisonment.
Defense counsel filed an Anders brief asserting no meritorious appeal issues but questioned denial of a two-level minor‑participant reduction under the Sentencing Guidelines.
Siddiqui filed a pro se brief raising: (1) entitlement to the minor‑participant reduction, (2) failure of the district court to consider mitigating circumstances at sentencing, (3) challenge to loss and restitution calculations, and (4) ineffective assistance of counsel.
The Fourth Circuit reviewed the sentence for procedural and substantive reasonableness under Gall and presumes a within‑Guidelines sentence is reasonable.
The court found Siddiqui’s admitted conduct essential to the fraud, upheld the Guidelines calculation (including loss/restitution), denied the minor‑participant reduction, and declined to resolve ineffective‑assistance claims on direct appeal, directing any such claim to § 2255.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Siddiqui was entitled to a two‑level minor‑participant reduction	Siddiqui: she was a minor participant and should receive the reduction	Government: her admitted role was essential to the conspiracy, so reduction not warranted	Denied; district court did not err in refusing reduction (role was essential)
Whether the sentence was procedurally unreasonable	Siddiqui: court failed to consider mitigating circumstances	Government: Guidelines were properly calculated and applied, and court considered relevant factors	No procedural error; calculation and consideration were proper
Whether loss and restitution amounts were excessive	Siddiqui: loss/restitution overstated	Government: calculations supported by record	Court affirmed loss and restitution amounts
Whether ineffective assistance of counsel can be raised on direct appeal	Siddiqui: counsel ineffective	Government: such claims are typically resolved in § 2255 collateral proceedings	Court declined to address on direct appeal and suggested § 2255 as proper vehicle

Anders v. California, 386 U.S. 738 (1967) (procedures for counsel to withdraw when appeal lacks merit)
Gall v. United States, 552 U.S. 38 (2007) (standards for reviewing procedural and substantive reasonableness of sentences)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within‑Guidelines sentences)
United States v. Pratt, 239 F.3d 640 (4th Cir. 2001) (minor‑participant reduction analysis)
United States v. Baptiste, 596 F.3d 214 (4th Cir. 2010) (ineffective assistance claims ordinarily raised in § 2255 proceedings)