United States v. Trayon Alphonse Caulton, 21-11035

In 2014 Caulton pled guilty to stealing firearms from a federal licensee and was sentenced to 57 months’ imprisonment plus 36 months’ supervised release.
His supervised release began August 21, 2018 and was due to expire August 20, 2021 (about seven months remained when the events in question occurred).
On January 29, 2021 Caulton was arrested for driving under the influence, violating conditions forbidding new crimes and excessive alcohol use; his probation officer filed a revocation petition.
At the revocation hearing Caulton admitted the violations and asked the court to follow the probation officer’s recommendation (which he believed required only continued supervision); the officer in fact recommended 3 months’ imprisonment and 6 months’ supervised release.
The district court revoked supervised release and sentenced Caulton to 9 months’ imprisonment followed by 3 months’ supervised release; Caulton appealed arguing procedural and substantive unreasonableness of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review / preservation	Caulton asserts sentence was substantively unreasonable and preserved objections to avoid plain-error review	Government urges plain-error review because Caulton did not adequately preserve all objections	Court applied abuse-of-discretion review for substantive claim (preserved); did not decide preservation for procedural claim because no procedural error found
Procedural reasonableness: Did court adequately consider §3553(a)?	Caulton says the court gave only a superficial statement and cursory reference to §3553(a) factors	Government and record show the court stated it considered Caulton’s arguments, his history, and §3553(a) purposes and Chapter 7 Guidelines	Court held no procedural error: district court sufficiently considered §3553(a) and explained its balancing
Substantive reasonableness: Weighting of factors	Caulton argues court overemphasized seriousness/deterrence and underweighted his favorable history/characteristics	Government points to discretion to weigh factors, sentence falling within guideline range and below statutory max	Court held sentence substantively reasonable: within policy range, below statutory max, and not a clear error in balancing

United States v. Trailer, 827 F.3d 933 (11th Cir. 2016) (defendant bears burden to show revocation sentence unreasonable)
United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014) (preservation and review standards for revocation sentencing issues)
Holguin-Hernandez v. United States, 140 S. Ct. 762 (2020) (clarifies preservation when defendant objects to substantive reasonableness)
Gall v. United States, 552 U.S. 38 (2007) (procedural-reasonableness principles and requirement to consider §3553(a))
United States v. Gomez, 955 F.3d 1250 (11th Cir. 2020) (scope of §3553(a) factors at supervised-release revocation and reasonableness indicators)
United States v. Sanchez, 586 F.3d 918 (11th Cir. 2009) (district court need not recite each §3553(a) factor on the record)
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) (standards for abuse of discretion in sentencing and improper factor weighting)
United States v. Dougherty, 754 F.3d 1353 (11th Cir. 2014) (appellate waiver principles)