Introduction

The case of UNITED STATES OF AMERICA v. Keonte Jamel White, decided by the United States Court of Appeals for the Eleventh Circuit on March 4, 2025, addresses critical issues in federal sentencing law. In this matter, defendant White challenged both the procedural and substantive aspects of his sentence, which resulted in a total incarceration of 80 months. White’s conviction involved a guilty plea for possession of a machinegun in violation of 18 U.S.C. § 922(o) and a jury trial conviction for possession of fentanyl under 21 U.S.C. § 844(a). The defendant primarily contended that the district court erroneously included conduct related to an acquittal in the sentencing decision and that his sentence substantially exceeded the applicable guideline range by 53 months.

This commentary examines the Judgment’s key elements including the background of the case, issues raised by the defendant, the court’s reasoning, and the implications of allowing sentencing courts to consider acquitted conduct, provided the government meets its evidentiary burden.

Summary of the Judgment

The Eleventh Circuit affirmed the district court’s sentence on two core grounds. First, the appellate court held that the district court did not commit any procedural error when it took into account the defendant’s acquitted conduct during sentencing, as long as the government satisfied its burden by proving such conduct by a preponderance of the evidence. Second, the appellate court found the overall sentence to be substantively reasonable despite an upward variance of 53 months above the guideline range. The court underscored that the district court had adequately justified its sentence by weighing the seriousness of White’s alleged offense, his history and characteristics, and the need to deter future criminal conduct.

Analysis

Precedents Cited

The Judgment relies on several seminal cases which have shaped sentencing jurisprudence:

• UNITED STATES v. WATTS, 519 U.S. 148 (1997): This case establishes that a jury’s acquittal does not preclude the sentencing court from considering other relevant conduct, so long as it is proven by a preponderance of the evidence.
• United States v. Cavallo, 790 F.3d 1202 (2015): The decision confirms that sentencing courts may consider acquitted conduct if the government meets its evidentiary burden, reinforcing the notion that an acquittal does not equate to a declaration of innocence regarding all aspects of the defendant’s conduct.
• United States v. Maddox, 803 F.3d 1215 (2015): This case reiterates that an acquittal by a jury merely indicates that the prosecution did not prove guilt beyond a reasonable doubt and does not prevent the consideration of related conduct during sentencing.
• United States v. Al Jaberi, 97 F.4th 1310 (2024): Cited to support the deferential abuse-of-discretion standard used to review sentencing decisions.
• United States v. Irey, 612 F.3d 1160 (2010): This case outlines the requirements under which the appellate court may determine that a sentence is substantively unreasonable.
• United States v. Dougherty, 754 F.3d 1353 (2014): Highlights the necessity for a compelling and complete justification when a sentencing court imposes a significant upward variance.

These precedents collectively influenced the court’s decision by providing a framework for when and how a sentencing court may incorporate conduct for which the defendant was acquitted, and by defining the scope and limits of judicial review in sentencing challenges.

Legal Reasoning

The court’s legal reasoning in this judgment is twofold:

• Procedural Considerations: The court confirmed that the district court was within its rights to consider conduct related to drug trafficking—even if acquitted—because the government had established that evidence of such conduct was more likely true than not. The reliance on preponderance-of-the-evidence standard was pivotal in demonstrating that the inclusion of this conduct did not represent a procedural error. By emphasizing that an acquittal does not prohibit the sentencing court from considering additional, proven conduct, the court refined the understanding of how acquitted actions are to be treated in sentencing.
• Substantive Reasonableness: The second prong of the court’s analysis focused on whether White’s sentence was markedly excessive. The court highlighted that the sentencing decision must satisfy the statutory mandates of § 3553(a), which require that the sentence reflects the nature of the offense, serves to deter, punishes justly, and protects the public. In this case, the 53-month upward variance was justified on the facts before the district court, which took into account White's multi-faceted conduct (including possession of weapons and fentanyl pills) as an indicator of his broader criminal involvement and potential threat. The court’s reliance on the factors outlined in established case law (e.g., Irey, Dougherty) supported its determination that the discretionary judgment applied was not so erroneous as to warrant reversal.

Impact on Future Cases and Legal Practice

This judgment is significant for several reasons:

• Clarification of Acquitted Conduct Consideration: The decision reaffirms that sentencing courts may consider acquitted conduct provided there is a preponderance of the evidence. This clarification is likely to guide lower courts and future litigants on the appropriate limits of using acquired evidence in sentencing, potentially affecting cases where the defendant’s behavior is multifaceted.
• Guidance on Upward Variance Justifications: The judgment underscores the necessity for robust justification when a sentencing court departs significantly from guideline ranges. This is especially relevant in cases where upward variances are sought on grounds of enhancing deterrence and public protection.
• Standardizing Deferential Review: By reiterating the criteria for procedural and substantive review — notably under the abuse-of-discretion standard — the ruling may enhance consistency in appellate review of sentencing decisions across the circuits.

Complex Concepts Simplified

Several legal concepts in the Judgment may seem dense; the following explanations aim to simplify them:

• Preponderance of the Evidence: This is a lower standard of proof than “beyond a reasonable doubt.” In the sentencing context, it allows the court to consider evidence that suggests it is more likely than not that the defendant engaged in certain conduct, even if he was not ultimately convicted on that count.
• Abuse-of-Discretion Standard: This legal standard compels appellate courts to defer considerably to the sentencing court’s judgment unless there is a clear error in reasoning or procedure. It means that even if an appellate court might have decided differently, it must respect the trial court’s decision unless it is demonstrably improper.
• Upward Variance: This refers to a sentence that deviates upward from the guideline range. The district court must provide compelling reasons to justify this disparity, such as the defendant’s history, the seriousness of the offense, and other relevant factors.

Conclusion

In summary, the Eleventh Circuit’s decision in UNITED STATES OF AMERICA v. Keonte Jamel White sets forth a significant precedent by validating the sentencing court’s consideration of acquitted conduct, as long as the prosecution meets the preponderance-of-the-evidence standard. Moreover, the Court’s detailed analysis of the procedural and substantive dimensions of sentencing reinforces the requirement for judicial restraint under the abuse-of-discretion standard while permitting necessary upward variances when strongly justified by the defendant’s conduct and background.

This decision not only clarifies the application of established sentencing principles but also provides valuable guidance for lower courts and future cases involving similar issues, ultimately contributing to a more uniform application of federal sentencing law.