No “Magic-Words” Requirement: The Fourth Circuit Re-Affirms Minimal-Explanation Standard for Compassionate-Release Denials

1. Introduction

In United States v. Larry Antonio Burleigh, No. 23-6254 (4th Cir. July 31 2025), the Court of Appeals for the Fourth Circuit confronted a familiar but increasingly litigated question: how much explanation must a district court give when it denies a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)? Defendant-Appellant Larry Burleigh, serving a 545-month sentence for carjacking and two “stacked” § 924(c) firearm counts, argued that the district court (1) disregarded the First Step Act disparity in his sentence, (2) failed to weigh his arguments collectively, and (3) gave a perfunctory discussion of the § 3553(a) factors. The majority opinion, authored by Judge Quattlebaum and joined by Judge Niemeyer, reaffirmed the Fourth Circuit’s “minimal-explanation” approach and held that the district court exceeded the amount of reasoning necessary for meaningful appellate review. Judge Gregory dissented, asserting that the majority misapplied the Circuit’s leading precedent, United States v. McCoy.

This commentary examines the judgment, its doctrinal context, and its practical ramifications for sentencing practice and post-sentence relief.

2. Summary of the Judgment

• Holding: The district court did not abuse its discretion in denying compassionate release; its explanation sufficiently allowed meaningful appellate review and properly applied existing precedent.
• Key Points:
  • District courts need not address every sub-argument or quantify sentence disparities so long as the reasoning process is apparent.
  • McCoy authorizes—but does not compel—sentence reduction because of pre-First-Step-Act § 924(c) stacking.
  • Courts may consider each proffered ground (rehabilitation, youth, sentence disparity) separately; they are not obliged to restate a “combined” analysis if the reasoning shows they were all considered.
• Outcome: Conviction and 545-month sentence remain intact; no remand for further explanation.

3. Analysis

3.1 Precedents Cited

The opinion canvasses a line of Supreme Court and Fourth Circuit cases that shape the compassionate-release landscape.

• Chavez-Meza v. United States, 585 U.S. 109 (2018) – establishes that a check-box form order may suffice when denying sentence-modification; provides “minimal explanation” benchmark.
• United States v. High, 997 F.3d 181 (4th Cir. 2021) – imports Chavez-Meza standard into § 3582(c)(1)(A) rulings; requires only enough detail for appellate review.
• United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) – recognizes that stacked § 924(c) sentences may constitute “extraordinary and compelling reasons.” The Burleigh majority clarifies that McCoy is permissive, not prescriptive.
• United States v. Bethea, 54 F.4th 826 (4th Cir. 2022) and United States v. Kibble, 992 F.3d 326 (4th Cir. 2021) – emphasize district courts’ broad discretion under § 3582(c)(1)(A).
• United States v. Reed, 58 F.4th 816 (4th Cir. 2023) & Concepcion v. United States, 597 U.S. 481 (2022) – confirm low bar for district-court explanation in sentence-modification contexts.

Judge Gregory’s dissent relied heavily on United States v. Brown, 78 F.4th 122 (4th Cir. 2023), and unpublished cases (Gutierrez, Davis) to argue that substantial rehabilitation and large First Step Act disparities demand a more robust rationale. The majority distinguished those cases as tethered to vastly different factual records or binding only when evidence of post-sentence change is extraordinary “by any measure.”

3.2 Legal Reasoning

1. Standard of Review. The majority meticulously reiterates the abuse-of-discretion rubric: an appellate court cannot re-weigh evidence but must find arbitrariness, reliance on erroneous premises, or legal error.
2. Extraordinary and Compelling Reasons.
   • The district court acknowledged each asserted basis (rehabilitation, youth, stacked sentences) and articulated why none—alone or in combination—cleared the statutory threshold.
   • The majority declares that “meaningful review” does not require numeric articulation of the exact 15-year disparity or statistical comparisons with other crimes.
3. § 3553(a) Factors.
   • District court emphasized the violent facts, victim impact, risk to public, and the fact that Burleigh had served only 27 % of his sentence.
   • The majority holds that repetition of the disparity analysis was unnecessary because the order “read as a whole” shows awareness of that argument.
4. Rejection of a “Combined-Factors” Mandate. The panel interprets “collective consideration” flexibly; a court may dispose of each proffered ground seriatim without a dedicated paragraph that melds them together.

3.3 Likely Impact

• Solidifies Minimal-Explanation Doctrine. Burleigh cements that district courts in the Fourth Circuit can satisfy appellate scrutiny with concise rationales; formalistic demands for numerical disparities or point-by-point rebuttals are disfavored.
• Narrows Force of McCoy. Litigants cannot rely on § 924(c) stacking disparities alone; courts retain absolute discretion to deem violent facts, criminal history, or time served determinative.
• Encourages Efficiency. Sentencing judges may craft shorter orders without fear of reversal, as long as they reference core arguments and statutory factors.
• Creates Circuit Tension. Other circuits (e.g., Sixth and Tenth) sometimes require more detailed discussion. Burleigh may widen inter-circuit dissonance, inviting eventual Supreme Court review.
• Dissent as Roadmap for Future Appellants. Judge Gregory’s dissent supplies arguments for heightened scrutiny when defendants present (a) decades-long disciplinary clean records, (b) extraordinary BOP accolades, or (c) truly “outlier” sentences.

4. Complex Concepts Simplified

• Compassionate Release (CR): A statutory safety-valve (§ 3582(c)(1)(A)) allowing courts to reduce sentences for “extraordinary and compelling reasons” once the Bureau of Prisons or the inmate files a motion.
• § 924(c) Stacking: Before 2018, multiple firearm counts in the same indictment triggered consecutive 5-year and 25-year mandatory minima—producing huge sentences. The First Step Act removed this “stacking” for future cases.
• “Meaningful Appellate Review” Standard: An order is sufficient if appellate judges can discern why the district judge ruled as he did, even if some arguments are omitted or only succinctly addressed.
• Abuse of Discretion: A deferential standard; appellate courts cannot overturn simply because they would have decided differently. Reversal requires showing irrationality, misapplication of law, or erroneous facts.

5. Conclusion

United States v. Burleigh reinforces a pragmatic ethos in Fourth-Circuit sentencing jurisprudence: district courts are gatekeepers whose discretionary denials of compassionate release will stand absent glaring errors. The opinion confirms that neither the First Step Act’s § 924(c) reforms nor laudable prison conduct automatically compel relief, and that courts are not tethered to any “magic-words” formula when drafting their orders. For defense counsel, the decision underscores the importance of compiling objectively exceptional post-sentence records and tailoring arguments to statutory factors. For prosecutors and judges, it provides assurance that concise, focused reasoning—so long as it touches the substance of the parties’ contentions—will pass appellate muster. Whether the Supreme Court will eventually harmonize the divergent interpretive approaches among circuits remains to be seen, but for now, in the Fourth Circuit, brevity with clarity is both lawful and sufficient.