United States v. William Brown, 973 F.3d 667

William Eric Brown appealed the district court’s revocation of his supervised release and sentence of 18 months’ imprisonment followed by 25 years of supervised release.
Brown admitted violating supervised release by missing mandatory substance‑abuse treatment for about six weeks and testing positive for alcohol three times.
The Sentencing Guidelines’ Chapter 7 policy statement recommended a 7–13 month range for revocation; Brown argued the court should have imposed a within‑range sentence and characterized his violations as “technical.”
The district court stated it considered the guidelines range but imposed 18 months based on the nature and circumstances of the violations, Brown’s substance‑use history and repeated breaches of trust, and the need to protect the public and deter future misconduct.
The Fourth Circuit reviewed the revocation sentence under the "plainly unreasonable" standard and affirmed, concluding the sentence was not procedurally or substantively unreasonable and therefore not plainly so.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 18‑month revocation sentence was plainly unreasonable	Brown: sentence is plainly unreasonable because the court failed to adopt a within‑Guidelines (7–13 mo) sentence and treated violations as technical	Government: district court exercised discretion, considered Guidelines and §3553(a) factors, and justified above‑range sentence	Affirmed — sentence not plainly unreasonable
Whether the district court adequately explained its sentence	Brown: court did not directly address his mitigation and request for within‑range punishment	Government: court explicitly considered and rejected within‑range sentence for stated reasons (nature of conduct, history, breach of trust, deterrence, public protection)	Affirmed — procedural explanation adequate
Whether the violations were only "technical" warranting lesser sanction	Brown: violations were technical (missed meetings, positive alcohol tests)	Government: violations, combined with persistent substance abuse and breaches of trust, warranted higher sanction	Affirmed — court properly considered seriousness and imposed appropriate sentence

United States v. Webb, 738 F.3d 638 (4th Cir. 2013) (district court has broad discretion on revocation sentences; affirm if within statutory max and not plainly unreasonable)
United States v. Padgett, 788 F.3d 370 (4th Cir. 2015) (distinguishes procedural and substantive reasonableness in revocation‑sentence review)
United States v. Slappy, 872 F.3d 202 (4th Cir. 2017) (sets review framework for revocation sentences and defines "plain" in plain‑error sense)