United States v. Terrance Paul Snow, 23-13420

Snow pled guilty in 2021 to conspiring to commit Hobbs Act robbery and was originally sentenced to probation, a downward variance from the suggested Guidelines range.
The district court originally calculated a Guidelines imprisonment range of 37 to 46 months, but after a four-level downward departure for substantial assistance, reduced it to 24 to 30 months, instead granting Snow 60 months’ probation.
Within two years, Snow violated his probation by possessing and brandishing a firearm at a bar, leading the court to revoke his probation.
Upon revocation, the post-violation Guidelines range for imprisonment was 4 to 10 months due to the nature of the violation and Snow’s criminal history.
The district court, finding that this lower range did not account for the seriousness of the offenses, imposed a 37-month sentence—the bottom of the original, pre-departure Guidelines range.
Snow appealed, arguing that the new sentence was both procedurally and substantively unreasonable.

Issue	Snow's Argument	Government's Argument	Held
Guidelines calculation after revocation	Court erred by referencing original 37-46 months (pre-departure) range instead of post-departure range	Court only required to consider the current 4-10 month range; above-Guidelines sentence justified by seriousness	No procedural error; court acted within discretion
Substantive reasonableness	37-month sentence excessive and overly punitive	Sentence needed to reflect seriousness, promote respect, and protect public	Sentence substantively reasonable

Gall v. United States, 552 U.S. 38 (Supreme Court requires abuse-of-discretion review for sentencing reasonableness)
United States v. Boone, 97 F.4th 1331 (allocates burden of showing unreasonableness on appellant)
United States v. Riley, 995 F.3d 1272 (clarifies standards for substantive reasonableness review)
United States v. Carpenter, 803 F.3d 1224 (district court discretion after probation revocation regarding Guidelines)