United States v. Tiffany Markle, 20-4366

Tiffany L. Markle pleaded guilty to conspiracy to distribute methamphetamine (21 U.S.C. §§ 841(b)(1)(C), 846).
The district court calculated a Guidelines range of 151–188 months, granted a three-level downward departure, and sentenced Markle to 120 months (the low end of the departure range).
Markle requested a lower sentence (a variance); the district court denied that request.
Appellate counsel filed an Anders brief asserting no meritorious appeal but raising whether the 120‑month sentence was erroneous; Markle received notice of her right to file a pro se brief and did not do so.
The Fourth Circuit reviewed the sentence under the abuse‑of‑discretion standard for procedural and substantive reasonableness.
The Fourth Circuit affirmed, concluding the district court properly calculated the Guidelines, considered § 3553(a) factors and Markle’s arguments, adequately explained its decision, and that Markle failed to rebut the presumption of reasonableness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 120‑month sentence was procedurally or substantively unreasonable / whether the district court erred in denying a lower variance	Markle (via Anders brief) contends the 120‑month sentence may be excessive and seeks review of denial of a lower sentence	Government defends the sentence as procedurally sound (proper Guidelines calculation, considered §3553(a), explained decision) and substantively reasonable	Affirmed: sentence is procedurally and substantively reasonable; district court did not abuse its discretion

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel filing brief when appeal is claimed frivolous)
Gall v. United States, 552 U.S. 38 (U.S. 2007) (abuse‑of‑discretion review of sentences; procedural and substantive reasonableness framework)
United States v. Torres‑Reyes, 952 F.3d 147 (4th Cir. 2020) (limits on appellate review of Guidelines departure decisions)
United States v. Fowler, 948 F.3d 663 (4th Cir. 2020) (procedural reasonableness standards for sentencing)
United States v. Nance, 957 F.3d 204 (4th Cir. 2020) (requirement for individualized assessment and explanation applying §3553(a))
United States v. Arbaugh, 951 F.3d 167 (4th Cir. 2020) (consideration of substantive reasonableness after procedural review)
United States v. Provance, 944 F.3d 213 (4th Cir. 2019) (substantive reasonableness assessed by totality of circumstances)
United States v. Smith, 919 F.3d 825 (4th Cir. 2019) (within‑Guidelines sentences are presumptively reasonable)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (defendant must show sentence unreasonable under §3553(a) to rebut presumption)