United States v. Vazquez-Vazquez, 852 F.3d 62

Vázquez pled guilty in 2011 to conspiracy to possess with intent to distribute controlled substances and was sentenced in 2012 to 24 months' imprisonment and eight years' supervised release (supervision began Feb. 18, 2014).
In June 2015 his probation officer alleged violations of supervised release; after an evidentiary hearing the district court found violations, including possession and discharge of a firearm in a public housing project and association with active drug dealers.
The firearm-related violation (18 U.S.C. § 922(g)) was treated as a Grade B supervised-release violation under U.S.S.G. § 7B1.1(a)(2).
With Vázquez in Criminal History Category II, the advisory Guidelines range for revocation was 6–12 months under U.S.S.G. § 7B1.4(a); both parties recommended a within-Guidelines sentence.
The district court revoked supervised release and imposed the statutory maximum of 36 months under 18 U.S.C. § 3583(e)(3), three times the Guidelines high end.
Vázquez appealed, arguing procedural error (insufficient explanation tied to § 3583(e)/§ 3553(a) factors) and substantive unreasonableness of the 36-month sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural adequacy of sentencing explanation	Gov't: District court adequately explained its findings and rationale based on the record and hearing	Vázquez: Court failed to explain its variance from Guidelines with reference to § 3583(e)/§ 3553(a) factors	No procedural error; court’s detailed factual findings and reference to defendant’s history sufficed (plain-error standard not met)
Substantive reasonableness of 36-month sentence	Gov't: Sentence justified by defendant’s recidivism risk and serious violations (public firearm discharge; quick reoffending after release)	Vázquez: Sentence excessive given no state charges for the firearm, his GED/college enrollment, difficult childhood, and learning disabilities	Sentence not substantively unreasonable; plausible rationale and defensible result, no abuse of discretion

United States v. Ruiz-Huertas, 792 F.3d 223 (1st Cir. 2015) (standards for reviewing sentencing court’s application of Guidelines and explanation)
United States v. Montero-Montero, 817 F.3d 35 (1st Cir. 2016) (plain-error standard for unpreserved sentencing claims)
United States v. Smith, 445 F.3d 1 (1st Cir. 2006) (greater guideline departures require more compelling justification)
United States v. Dean, 414 F.3d 725 (7th Cir. 2005) (same principle regarding degree of departure and required explanation)
United States v. Franquiz-Ortiz, 607 F.3d 280 (1st Cir. 2010) (district court’s inadequate explanation for a maximum revocation sentence)
United States v. Pulido, 566 F.3d 52 (1st Cir. 2009) (sentencing court need not address each § 3553(a) factor in rote fashion)
United States v. Pérez, 819 F.3d 541 (1st Cir. 2016) (standard of review for revocation-sentence challenges)
United States v. Martin, 520 F.3d 87 (1st Cir. 2008) (plausible sentencing rationale and defensible result as linchpin of reasonableness)
United States v. Guzman-Fernandez, 824 F.3d 173 (1st Cir. 2016) (greater variance demands more compelling justification)
United States v. Vargas-García, 794 F.3d 162 (1st Cir. 2015) (sentencing court’s discretion to weigh mitigating and aggravating factors)