United States v. Taylor
907 F.3d 1046
| 7th Cir. | 2018Background
- Taylor and Thomas participated in a 2000 armed robbery of a gun shop during which Taylor shot and killed the 73‑year‑old owner; both were convicted of multiple counts including felony murder under 18 U.S.C. § 924(j).
- The case had a long procedural history (multiple appeals and a retrial), with resentencing ordered and later conducted in 2017; both defendants received within‑Guidelines life sentences for the felony‑murder count.
- At resentencing each urged substantial mitigation under 18 U.S.C. § 3553(a): traumatic childhoods, substance exposure, mental‑health problems, low IQ scores (in Taylor’s earlier testing), and institutional rehabilitation.
- The district judge explicitly considered those mitigating factors but concluded the defendants made conscious choices to engage in violent crime and that life sentences were necessary for punishment and deterrence.
- On appeal the defendants did not assert procedural error in the sentencing court’s consideration of mitigation, but argued the life sentences were substantively unreasonable in light of their backgrounds and post‑offense rehabilitation.
- The Seventh Circuit affirmed: because the sentences were within the properly calculated Guidelines range and the district court adequately addressed § 3553(a) factors, the appellate court presumed the sentences reasonable and found no basis to rebut that presumption.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether life sentences were substantively unreasonable under § 3553(a) | Taylor/Thomas: traumatic youth, low IQ/mental illness, prison rehabilitation, and sentencing averages warrant substantial below‑Guidelines sentences (30 years) | District court: considered mitigation but emphasized defendants' personal choices, heinous facts, criminal history, and deterrence needs | Affirmed — within‑Guidelines life sentences presumed reasonable; defendants failed to rebut presumption |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory strike discrimination standard)
- United States v. Faulkner, 885 F.3d 488 (7th Cir. 2018) (within‑Guidelines sentences carry a presumption of reasonableness)
- United States v. Tanner, 628 F.3d 890 (7th Cir. 2010) (presumption applies even to life sentences within the Guidelines)
- United States v. Lewis, 842 F.3d 467 (7th Cir. 2016) (sentencing review is for abuse of discretion)
- United States v. Solomon, 892 F.3d 273 (7th Cir. 2018) (defendant bears burden to rebut presumption by showing inconsistency with § 3553(a) factors)
- United States v. Horton, 770 F.3d 582 (7th Cir. 2014) (district court need only provide adequate justification to allow meaningful appellate review)
- United States v. Warner, 792 F.3d 847 (7th Cir. 2015) (appellate court will not substitute its judgment for the sentencing court's reasonable weighing)
- United States v. Volpendesto, 746 F.3d 273 (7th Cir. 2014) (life sentences should not be imposed lightly; require careful evaluation)