By Chad M. Zimlich
Today, in the case of United States v. Mitchell, the Fourth Circuit ruled on the reasonableness of a sentence handed down by the Eastern District of North Carolina. Mr. Jeromey Keith Mitchell pleaded guilty to “conspiracy to distribute and to possess with intent to distribute 280 grams or more of cocaine base, six counts of distributing cocaine base, and one count of possession with intent to distribute cocaine base.” The court sentenced him to 22 years in prison.
Mitchell filed an appeal, arguing that the sentence was “substantively unreasonable.”
In reviewing whether a criminal sentence is reasonable or not, the court uses an “abuse of discretion” standard. First the court must examine any glaring procedural errors, and second the court examines the “totality of the circumstances” viewed in the light most favorable to the district court and its decision.
In examining the district court’s calculation of the defendant’s Guidelines range, the Fourth Circuit determined that the actual Guidelines range for Mitchell was 292 to 365 months. The district court’s sentence of 22 years, or 264 months, was 28 months below the low-end of the spectrum, and well within their authority in the realm of reasonableness.
Furthermore, the Fourth Circuit felt the district court’s use of the factors under 18 U.S.C. § 3553(a) in assessing an appropriate sentence based on the “totality of the circumstances” was founded on a thorough, individualized assessment of Mitchell’s case. The district court did not abuse its discretion, and the Fourth Circuit therefore affirmed Mitchell’s sentence.