United States v. Willie Robinson
713 F. App'x 514
| 8th Cir. | 2017Background
- Robinson pleaded guilty to being a felon in possession of a firearm, received 180 months and four years supervised release, and began supervised release July 14, 2016.
- Probation reported multiple positive drug tests and a failure to appear for shock incarceration; Robinson admitted the violations at a show-cause hearing.
- Defense counsel argued Robinson struggles with supervision due to mental health issues (competency review indicating mildly mentally retarded range; prior head injury and seizures) and requested a 12-month-and-a-day sentence.
- Probation recommended 30 months; the government recommended a sentence within the Guidelines range of 6–12 months followed by supervised release and opposed eliminating supervision.
- The district court sentenced Robinson to 20 months’ imprisonment and no supervised release, explaining it viewed 30 months as extreme, doubted additional prison would cure his drug use, but rejected an overly lenient sentence that might incentivize violating supervision to avoid future supervision.
- Robinson appealed, arguing the 20-month sentence was substantively unreasonable because the district court failed to consider his mental disability as a mitigating factor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 20-month revocation sentence is substantively unreasonable for failing to consider defendant's mental disability | Robinson: court failed to consider his mental disability as a mitigating factor, making the sentence unreasonable | Government/District Court: court considered arguments, weighed factors, and reasonably exercised discretion in choosing 20 months with no supervision | Affirmed — no abuse of discretion; court considered mental-health arguments and provided a reasoned basis for sentence |
Key Cases Cited
- United States v. Benton, 627 F.3d 1051 (8th Cir. 2010) (applies reasonableness standard on supervised-release revocation review)
- United States v. Merrival, 521 F.3d 889 (8th Cir. 2008) (reasonableness standard citation for revocation review)
- United States v. Lisenbery, 866 F.3d 934 (8th Cir. 2017) (per curiam) (substantive-reasonableness review is deferential abuse-of-discretion)
- United States v. Kreitinger, 576 F.3d 500 (8th Cir. 2009) (district court abuses discretion if it fails to consider a significant factor or gives improper weight)
- United States v. Williams, 624 F.3d 889 (8th Cir. 2010) (district court need not respond to every argument; explanation may vary)
- United States v. Key, 832 F.3d 837 (8th Cir. 2016) (district court must set forth enough to show it considered parties' arguments)
- United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (reversal for substantive unreasonableness is unusual)