United States v. William Morris, 918 F.3d 595

William Morris was convicted of four federal counts including aiding and abetting attempted murder and assault in aid of racketeering, a § 924(c) firearms count, and being a felon in possession under § 922(g)(1).
At initial sentencing the court applied the Armed Career Criminal Act (ACCA) enhancing the felon-in-possession sentence to 360 months, plus a consecutive 60 months on the § 924(c) count, for a total of 420 months; concurrent terms were imposed for the racketeering-related counts.
On first appeal this Court held Morris was not an armed career criminal because his Minnesota burglary convictions were not violent felonies under § 924(e)(1), vacating the ACCA-based sentence. United States v. McArthur, 850 F.3d 925 (8th Cir. 2017).
On remand the district court resentenced: retained the concurrent 120- and 240-month terms for the racketeering counts, reduced the felon-in-possession term to the statutory maximum of 120 months, and imposed a 140-month consecutive term on the § 924(c) count, producing a 380-month total.
Morris appealed, claiming procedural error (inadequate explanation of the new sentence) and substantive unreasonableness (sentence excessive given removal of ACCA), arguing the court should have imposed a 300-month total instead.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court gave an adequate explanation for the resentencing	Morris: court failed to provide sufficient reasons for the new 380-month aggregate sentence and did not respond to non-frivolous arguments	Government: judge reviewed materials, heard argument, addressed factors and Morris’s objections, and explained basis for total sentence	Court held explanation sufficient; no procedural error (judge considered statutory factors and parties’ arguments)
Whether the 380-month sentence is substantively unreasonable	Morris: sentence is "grossly excessive" absent ACCA; court should have imposed 300 months (reduce felon-in-possession to 120, keep prior 60-month § 924(c) consecutive term)	Government: advisory guideline “functional” range supported a heavy sentence; district court permissibly balanced § 3553(a) factors and already varied below guideline range	Court held sentence not substantively unreasonable; no abuse of discretion
Whether district court improperly weighed state sentences and absence of ACCA	Morris: court gave insufficient weight to lower state sentences and loss of ACCA enhancement	Government: district court addressed and reasonably discounted these factors in light of federal sentencing purposes	Court held district court reasonably weighed factors; no reversible error

Gall v. United States, 552 U.S. 38 (2007) (standard for procedural and substantive reasonableness review of sentences)
Rita v. United States, 551 U.S. 338 (2007) (requirements for district court explanation of chosen sentence)
United States v. Gray, 533 F.3d 942 (8th Cir. 2008) (district court need not address every reasonable argument specifically)
United States v. McArthur, 850 F.3d 925 (8th Cir. 2017) (defendant’s prior Minnesota burglary convictions did not qualify as violent felonies under ACCA)
United States v. Chavarria-Ortiz, 828 F.3d 668 (8th Cir. 2016) (presumption that within-guideline sentences are reasonable)
United States v. Lazarski, 560 F.3d 731 (8th Cir. 2009) (court unlikely to abuse discretion by declining to vary downward further when already varying below guideline range)