Failure to Explain Sentence Plainly Unreasonable
In US v. Thompson, No. 09-4247, the Fourth Circuit dealt with a criminal defendant's challenge to revocation of his supervised release and sentencing him to 18 months' imprisonment.
As noted by the circuit court, "A district court commits significant procedural error where it "fail[s] to adequately explain the chosen sentence." Gall v. United States, 552 U.S. 38, 51 (2007)." Further, "The district court provided no such statement here. Instead, it simply stated: 'It's the judgment of the Court the defendant be committed to the custody of the Federal Bureau of Prisons for a term of 18 months.'"
Although the circuit court "may be hard-pressed to find any explanation for within-range, revocation sentences insufficient given the amount of deference we afford district courts when imposing these sentences ... [nevertheless] a district court may not simply impose sentence without giving any indication of its reasons for doing so."
In reversing the sentence, the court concluded that the district court's failure to provide any reasons for the sentence it imposed was plainly unreasonable.