United States v. Terence Garmon, 20-4619

Appellant: Terence Devon Garmon appealed the revocation of his supervised release and the sentence imposed.
District court sentence: 1 year and 1 day imprisonment followed by two years of supervised release after revocation.
Garmon’s principal argument on appeal: the sentence was procedurally unreasonable because the district court failed to adequately address his nonfrivolous request for a time-served sentence.
Governing framework: courts review revocation sentences more deferentially than original sentences and require consideration of Chapter Seven policy statements and 18 U.S.C. § 3553(a) factors.
Circuit precedent requires the sentencing court to address nonfrivolous mitigating arguments and explain why they are rejected to permit meaningful appellate review.
Outcome: The Fourth Circuit affirmed, concluding the district court adequately addressed Garmon’s arguments and provided sufficient reasons for the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the revocation sentence was procedurally unreasonable for failing to address Garmon’s nonfrivolous request for time-served	Garmon: district court did not adequately consider or explain rejection of his nonfrivolous arguments for time-served	Government: district court considered the arguments, applied the proper factors, and gave adequate reasons for the imposed term	Affirmed — court adequately addressed the nonfrivolous arguments and the sentence was procedurally reasonable

United States v. Patterson, 957 F.3d 426 (4th Cir. 2020) (articulates deference and plain-unreasonableness standard for revocation sentences)
United States v. Padgett, 788 F.3d 370 (4th Cir. 2015) (explains more deferential review for revocation sentences versus original sentences)
United States v. Coston, 964 F.3d 289 (4th Cir. 2020) (procedural reasonableness requires considering Chapter Seven and § 3553(a) factors)
United States v. Blue, 877 F.3d 513 (4th Cir. 2017) (sentencing court must provide sufficient explanation showing it considered parties’ arguments)
United States v. Slappy, 872 F.3d 202 (4th Cir. 2017) (court must address nonfrivolous arguments and explain rejection)
United States v. Ross, 912 F.3d 740 (4th Cir. 2019) (supports requirement to address nonfrivolous sentencing arguments)
United States v. Lewis, 958 F.3d 240 (4th Cir. 2020) (failure to give specific attention to nonfrivolous arguments generally yields procedural unreasonableness)