United States v. Terrance Williams, 683 F. App'x 189

Terrance Williams pleaded guilty in 2010 to a § 924(c) firearm offense; a related § 922(g) conviction was later vacated on appeal under United States v. Simmons.
On remand Williams was sentenced to 60 months imprisonment and five years supervised release for the § 924(c) count; standard conditions included no new crimes and drug testing.
Williams admitted to drug use days after release, incurred state charges, tested positive for oxycodone and later marijuana, and admitted a marijuana-positive test in December 2015.
The probation officer moved to revoke his supervised release; Williams admitted the violations at the revocation hearing.
The district court departed upward from the Chapter 7 advisory range (8–14 months) and imposed a 36-month custodial revocation sentence, citing repeated violations and a lengthy criminal history.
Williams appealed, arguing the sentence was procedurally and substantively unreasonable and impermissibly punished his original offense rather than the release violation.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (Government)	Held
Procedural reasonableness of upward departure	Court failed to show it considered Chapter 7 policy statements and § 3553(a) factors	District court adequately explained reasons (repeated violations, criminal history, lack of deterrence)	Affirmed — explanation sufficed for meaningful appellate review
Substantive reasonableness of 36‑month sentence	Sentence punished original offense and was excessive relative to Chapter 7 range	Sentence reflected breach of trust, recidivism, and criminal history; within statutory maximum	Affirmed — substantive basis supported by record
Whether court relied impermissibly on seriousness of underlying offense	Court impermissibly focused on original offense seriousness to justify revocation term	Mere reference to original sentence (post‑Simmons) was contextual and tied to § 3553(a) factors	Affirmed — permissible when considered with proper § 3553(a) factors
Whether court should have ordered drug treatment instead of prison	Williams sought treatment as alternative to incarceration	District court previously provided aftercare; repeated violations and failed tests justified incarceration	Affirmed — court did not abuse discretion in declining treatment alternative

United States v. Simmons, 649 F.3d 237 (4th Cir. 2011) (holding affecting felon‑in‑possession predicate analysis)
United States v. Crudup, 461 F.3d 433 (4th Cir. 2006) (upholding substantially higher revocation sentence where defendant repeatedly violated supervision)
United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (discussing limits on factors for revocation sentencing and appellate review standard)
Gall v. United States, 552 U.S. 38 (2007) (district courts must adequately explain chosen sentence to permit meaningful appellate review)
United States v. Moulden, 478 F.3d 652 (4th Cir. 2007) (district court need not recite § 3553(a) mechanically; context can suffice)
United States v. Thompson, 595 F.3d 544 (4th Cir. 2010) (sentences are plainly unreasonable only if they conflict with clearly settled law)