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A court of appeals can apply a presumption of reasonableness to a district court sentence that reflects a proper application of the U.S. Sentencing Guidelines Manual.
Rita was convicted of offenses related to providing false testimony to a grand jury, but defendant asserted that his sentence was improperly subjected to a presumption of reasonableness on review and that the sentence was unreasonable. Upon the grant of a writ of certiorari, defendant appealed the judgment of the United States Court of Appeals for the Fourth Circuit which affirmed defendant's sentence. Rita contended that lower appellate court review of his sentence improperly applied a presumption of reasonableness merely because the sentence was within the range properly calculated under the U.S. Sentencing Guidelines Manual (Guidelines). Rita also argued that the sentencing court failed to explain sufficiently its reasons for declining a lower sentence based on defendant's health, his fear of abuse in prison, and his distinguished military service.
Was Rita’s sentence improperly subjected to a presumption of reasonableness?
The U.S. Supreme Court first held that the lower appellate court properly applied a presumption of reasonableness to Rita’s within-Guidelines sentence, since the presumption was not binding, did not reflect strong judicial deference, and merely recognized that a sentencing court's discretionary sentence which was also in accord with the advisory Guidelines was probably reasonable. Further, the sentencing court's statement of reasons, albeit brief, sufficiently indicated that Rita’s arguments for a lower sentence were considered and deemed to be inadequate to warrant leniency outside the Guidelines, and the circumstances identified by Rita were not in fact special enough to warrant a lower sentence.