Affirmance of Substantively Reasonable Sentences Within the Guidelines “Ballpark” under §3553(a) for §922(g) Offenses

Introduction

In United States v. Tarrence Lee Wright, the Eleventh Circuit considered whether a 120-month term of imprisonment, imposed on a convicted felon for possession of a firearm in violation of 18 U.S.C. § 922(g)(1), was substantively unreasonable. Tarrence Wright, who had a prior Alabama felony conviction and was prohibited from possessing a weapon, admitted firing a 9 mm handgun both outside a third party’s home and within his own residence during an apparent domestic struggle. The district court calculated an advisory Guidelines range of 100–125 months, weighed the factors under 18 U.S.C. § 3553(a), and selected a 120-month sentence. Wright appealed, arguing that the sentence was excessive in light of mitigating circumstances in his background and criminal history. The government opposed the appeal. The Eleventh Circuit, applying a deferential abuse-of-discretion standard, affirmed the sentence.

Summary of the Judgment

The Court of Appeals, in a per curiam opinion, held that Wright’s within-Guidelines sentence is substantively reasonable. Key holdings include:

The appellate court reviews substantive reasonableness under an abuse-of-discretion standard (Gall v. United States) and will affirm so long as the sentence lies within the “ballpark of permissible outcomes.”
A sentence within the correctly calculated advisory range and well below the statutory maximum creates a strong presumption of reasonableness.
The district court appropriately considered Wright’s violent conduct, extensive criminal history, and the need to protect the public under § 3553(a).
The court did not err by not discussing every mitigating argument in depth; the sentencing record shows the district court considered all relevant factors.

The Eleventh Circuit concluded that Wright had not met his burden to show the 120-month term was substantively unreasonable and therefore affirmed the judgment.

Analysis

Precedents Cited

Gall v. United States (552 U.S. 38, 2007): Established the two-step abuse-of-discretion review for substantive reasonableness: (1) procedural soundness; (2) assessment under § 3553(a) factors.
United States v. Trailer (827 F.3d 933, 2016): Clarified that courts must examine the totality of circumstances, with deference to district courts on weight accorded obstacles.
United States v. Butler (39 F.4th 1349, 2022): Reiterated that a within-Guidelines sentence is presumptively reasonable and lies within the permissible “ballpark.”
United States v. Boone (97 F.4th 1331, 2024): The defendant challenging reasonableness bears the burden of proof.
United States v. Ortiz-Delgado (451 F.3d 752, 2006): Confirmed that a district court need not expressly discuss every § 3553(a) factor so long as the record shows consideration.
United States v. Rosales-Bruno (789 F.3d 1249, 2015): Permitted substantial weight on criminal history, recognizing that multiple § 3553(a) factors relate to defendant’s past record.
United States v. Amedeo (487 F.3d 823, 2007): Held that consideration of a factor in a Guidelines enhancement does not preclude its use in sentencing considerations.

Legal Reasoning

The Eleventh Circuit’s reasoning unfolded in several steps:

Standard of Review: The court reiterated its deferential abuse-of-discretion review. It must first ensure no significant procedural error occurred, then evaluate whether the sentence is substantively reasonable under § 3553(a).
Presumption of Reasonableness: Wright’s 120-month sentence fell within a properly calculated Guidelines range (100–125 months) and below the 15-year statutory maximum. Such a sentence ordinarily warrants affirmance unless the defendant rebuts the presumption.
Application of § 3553(a) Factors: The district court expressly weighed:
- The nature and circumstances of Wright’s offenses, which included shooting a firearm twice—once into the air near a third party’s residence and once during a domestic struggle.
- Wright’s history and characteristics, including a lengthy criminal record of violent and weapon-related offenses.
- The need to promote respect for law, provide just punishment, and protect the public from further violent crime.
- The need for deterrence, given Wright’s repeated violations despite earlier convictions.
Consideration of Mitigating Evidence: Although the district court did not recite every mitigating argument on the record, it reviewed a psychological evaluation detailing Wright’s traumatic upbringing, mental-health diagnoses, and accepted defense counsel’s request for a downward variance. Ultimately, the court found these factors insufficient to outweigh the seriousness of the offense and Wright’s escalating criminal conduct.
Conclusion of Reasonableness: Given the violent facts, robust criminal history, and discretionary deference, the appellate court held Wright failed to demonstrate that a 120-month sentence was substantively unreasonable.

Impact

This decision reinforces key sentencing principles:

It solidifies the strong presumption of reasonableness accorded to within-Guidelines sentences under § 3553(a).
It underscores the broad discretion district courts have in weighing aggravating and mitigating factors—particularly criminal history and public-safety concerns.
It clarifies that an appellate court will not reweigh evidence or second-guess the district court’s assessment if the sentence remains in the Guidelines “ballpark.”
It affirms that taking into account a factor for both an enhancement and the ultimate sentence does not constitute impermissible double counting, so long as the sentencing judge explains the justification.

Complex Concepts Simplified

Abuse-of-Discretion Standard: A deferential review where an appellate court upholds a lower court’s decision unless it was arbitrary, unreasonable, or not grounded in sound legal principles.
Advisory Guidelines Range: The sentencing range suggested by the U.S. Sentencing Guidelines, which district courts must calculate and consider but are not strictly bound to impose.
“Ballpark” of Permissible Outcomes: A metaphor expressing that any within-Guidelines sentence is generally acceptable unless extraordinary circumstances exist.
§ 3553(a) Factors: Ten considerations outlined in 18 U.S.C. § 3553(a) guiding judicial discretion at sentencing, including offense seriousness, history and characteristics of the defendant, deterrence, and public protection.

Conclusion

United States v. Wright stands as a clear affirmation of the deferential “abuse-of-discretion” standard in sentencing appeals. By upholding a within-Guidelines sentence for a violent § 922(g) offense, the Eleventh Circuit underscores that properly calculated Guidelines ranges, when grounded in the § 3553(a) factors and supported by record findings, will rarely be overturned on substantive-reasonableness grounds. The decision reinforces district courts’ broad discretion in weighing violent conduct and criminal histories against mitigating personal circumstances, ensuring that sentences remain firmly tethered to both principled sentencing guidelines and the goals of justice.