United States v. Young, 640 F.3d 846

Young pled guilty in July 2007 to felon in possession of a firearm, with multiple prior DWI and related offenses.
In October 2009, Young began three years of supervised release with a strict alcohol prohibition and VICAP testing.
During a July 2010 home visit, officers observed alcohol on Young and he admitted drinking; he initially lied about it.
From October to early November 2010, Young failed to provide seven breath samples for VICAP; later, he tested positive for alcohol in December 2010.
District court modified supervised release to impose two consecutive weekends in jail after VICAP failures, but further noncompliance occurred.
In December 2010 the government petitioned to revoke supervised release; Young admitted violations and the guidelines range was 5–11 months; the district court sentenced him to 8 months in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural error in revocation sentencing	Young argues the court failed to explain how revocation advanced §3553(a) goals.	Government contends the court clearly reflected §3553(a) factors and did not err procedurally.	No procedural error; explanation adequate.
Substantive reasonableness of an 8-month sentence	Young contends imprisonment was unnecessary given stability and progress on release.	Government argues middle-of-range sentence appropriate given prior noncompliance and limited effect of lesser sanctions.	Not substantively unreasonable; within the proper range.

United States v. Thunder, 553 F.3d 605 (8th Cir. 2009) (deferential abuse-of-discretion standard for revocation sentences; need not list every §3553(a) factor)
United States v. Merrival, 521 F.3d 889 (8th Cir. 2008) (analysis of reasonableness of revocation within guideline range)
United States v. Bear Robe, 521 F.3d 909 (8th Cir. 2008) (illustrates appropriate consideration of §3553(a) factors in revocation)
Gall v. United States, 552 U.S. 38 (U.S. 2007) (requires explanation of chosen sentence, not rejection of alternatives)