Procedural Reasonableness: No Reversal When Sentencing Misstatements Are Corrected and the § 3553(a) Rationale Is Adequately Explained

I. Introduction

In United States v. Alexander Beattie (6th Cir. May 18, 2026) (unpublished), the Sixth Circuit affirmed an above-Guidelines sentence imposed after the defendant pleaded guilty to four firearm offenses (involving 3D-printed, unserialized firearms and related conduct) and one count of possessing child pornography. The district court calculated a Guidelines range of 151–188 months and imposed an upward variance to 210 months.

On appeal, Beattie did not contest the substantive length of the sentence; instead, he challenged its procedural reasonableness, arguing that the district court relied on erroneous facts or inconsistent statements at sentencing. The panel (Larsen, J.) rejected each procedural attack and held that the record—particularly the district court’s corrections and explanation tied to 18 U.S.C. § 3553(a)—supported affirmance.

II. Summary of the Opinion

The Sixth Circuit held that the sentence was procedurally reasonable because the district court: (1) properly calculated the Guidelines range; (2) considered the § 3553(a) factors; and (3) adequately explained why an above-Guidelines sentence was warranted—especially given Beattie’s extensive criminal history, violence (including multiple domestic-violence convictions), and the harm associated with possession of child pornography.

Addressing Beattie’s three factual/procedural objections, the panel concluded:

• Any initial misunderstanding about how Beattie’s misdemeanors came to be classified was corrected on the record and did not undermine the district court’s permissible concern that his repeated lawbreaking had not resulted in meaningful consequences.
• The district court’s comment that it did not come to the bench intending an upward variance—even though it had given pre-hearing notice it was considering one—did not establish procedural error absent any showing that the statement affected the sentence.
• Although the court initially misstated that Beattie made certain anti-gun-control remarks to the probation officer, that error was corrected during the hearing; by the time of sentencing, the court understood the remarks were Facebook messages obtained during the investigation and permissibly treated them as relevant to deterrence and protection of the public under § 3553(a)(2)(B) and (C).

III. Analysis

A. Precedents Cited

1. United States v. Rayyan, 885 F.3d 436 (6th Cir. 2018)

The opinion uses United States v. Rayyan as the organizing framework for procedural-reasonableness review. Rayyan lists the core requirements: correct Guidelines calculation, advisory treatment of the range, consideration of § 3553(a), avoidance of impermissible factors, reliance on non-clearly-erroneous facts, and an adequate explanation. By anchoring its analysis to Rayyan, the panel evaluated Beattie’s claims as classic procedural attacks—each tied to whether the sentencing judge relied on a clearly erroneous fact or otherwise failed to follow required sentencing steps.

2. United States v. Parrish, 915 F.3d 1043 (6th Cir. 2019)

United States v. Parrish supplies the rule for preservation and standard of review: procedural challenges are usually reviewed for abuse of discretion, but unpreserved claims are reviewed for plain error. Notably, the panel declined to resolve the parties’ preservation dispute because, under either standard, “the district court didn’t err.” This maneuver underscores a practical appellate approach: when the record demonstrates no procedural defect, the court can affirm without choosing between abuse-of-discretion and plain-error review.

3. United States v. Herrera-Zuniga, 571 F.3d 568 (6th Cir. 2009)

Beattie argued the court improperly assessed his criminal-history consequences. The panel invoked United States v. Herrera-Zuniga to confirm that a sentencing court may consider whether a defendant has previously avoided meaningful consequences for repeated criminal conduct. That principle directly supported the district court’s emphasis on Beattie’s sustained pattern of lawbreaking and the perceived failure of past interventions to deter him—an assessment tied to § 3553(a)’s deterrence and public-protection aims.

4. United States v. Green, 167 F.4th 832 (6th Cir. 2026)

The panel cited United States v. Green for the character of “clear error” review—described as “deferential.” This mattered because Beattie’s procedural claims largely depended on labeling aspects of the sentencing judge’s factual understanding as clearly erroneous. By emphasizing deference, Green supported affirmance where the record reasonably supported the district court’s overall conclusions, especially once corrections were made on the record.

B. Legal Reasoning

1. The core procedural question: did the sentencing judge rely on incorrect facts or improper factors?

Beattie’s appeal targeted the “facts that are not clearly erroneous” component of procedural reasonableness. The panel’s reasoning is best understood as a two-step inquiry:

1. Was there an inaccuracy or questionable statement at sentencing? The panel acknowledged that the district judge made some statements that could be read as mistaken or inconsistent (e.g., speculation about why misdemeanors were misdemeanors; confusion about whether “FGC” comments were made to probation).
2. Did any misstatement actually infect the sentencing decision? The panel emphasized the record corrections: the judge accepted counsel’s clarification about the misdemeanors and later showed an accurate understanding of the Facebook messages’ timing/source. In short, the court did not sentence on a materially false premise.

2. Criminal history: permissible assessment despite an initial misconception

The district court initially speculated that misdemeanors might reflect plea negotiations or victim nonappearance. Defense counsel corrected that point. The panel treated this as non-dispositive because the district court expressly acknowledged counsel was “right” and ultimately grounded its sentencing rationale in uncontroverted facts: a long juvenile record, numerous misdemeanors, two felonies, and multiple domestic-violence convictions. Under Herrera-Zuniga, the court could permissibly consider the broader theme that prior encounters with the justice system failed to deter Beattie.

3. Notice and the upward-variance comment: no procedural defect without demonstrated effect

Beattie highlighted an apparent inconsistency: the judge had provided pre-sentencing notice that an upward variance was being considered, yet stated at the hearing that it “did not come on the bench” expecting to impose one. The panel rejected this as a basis for reversal because:

• The statement could reflect the judge’s evolving view during the hearing, not a factual error about notice.
• Even if in tension with earlier notice, Beattie did not connect the statement to any concrete procedural harm (e.g., impaired ability to argue mitigation).

The reasoning reflects a practical appellate principle: a defendant must show that an alleged procedural irregularity mattered to the sentencing decision, not merely that the record contains an awkward or arguably inconsistent remark.

4. Facebook “FGC” comments: initial misattribution corrected; relevance properly tied to § 3553(a)

Beattie argued the court relied on clearly erroneous facts when it initially indicated the anti-gun-control comments were made to the probation officer. The transcript showed the probation officer corrected the record, both parties confirmed the correction, and the judge thanked them. Crucially, when later addressing the comments, the judge described them as relevant to Beattie’s mindset “at the time that he was committing these crimes” and linked them to deterrence and protection of the public—explicitly invoking § 3553(a)(2)(B) and (C) concepts. The panel therefore treated the episode as a corrected misstatement, not a sentencing decision based on false information.

C. Impact

Although unpublished and therefore not precedential in the same manner as a published Sixth Circuit opinion, the decision is still instructive for sentencing practice:

• Record correction matters. When an inaccuracy arises at sentencing, timely clarification by probation or counsel—and acknowledgement by the court—can neutralize later claims that the sentence rested on false facts.
• Appellate focus is on material reliance. The opinion reinforces that not every misstatement is reversible error; the key question is whether the district court ultimately relied on a materially erroneous fact in imposing sentence.
• “Mindset” evidence can be relevant to § 3553(a). The court accepted that social-media statements reflecting attitude toward legality/regulation may bear on deterrence and risk of recidivism, particularly when tied to the charged conduct.
• Upward variances remain highly explanation-dependent. The district court’s extensive walkthrough of Beattie’s history and the unusual combination of firearm manufacturing and child pornography was central to affirmance.

IV. Complex Concepts Simplified

• Procedural reasonableness: Whether the judge followed the required sentencing process (correct Guidelines, considered § 3553(a), used accurate facts, and explained the sentence). It is distinct from whether the sentence is “too long” (substantive reasonableness).
• Guidelines range: The advisory sentencing range calculated under the U.S. Sentencing Guidelines, based on offense characteristics and criminal history.
• Upward variance: A sentence above the Guidelines range based on § 3553(a) factors (as opposed to a “departure,” which is a Guidelines-authorized adjustment).
• Clear error (factual review): A deferential standard; the appellate court will not overturn factual findings unless left with a definite and firm conviction a mistake was made.
• Plain error vs. abuse of discretion: If an objection wasn’t preserved, the defendant faces a higher hurdle (plain error). If preserved, review is typically for abuse of discretion. Here, the court affirmed without deciding which applied because it found no error under any standard.

V. Conclusion

United States v. Alexander Beattie affirms an above-Guidelines sentence against procedural attack by emphasizing two themes: (1) sentencing courts may rely on broad, § 3553(a)-grounded assessments—such as persistent criminal conduct without meaningful deterrent effect—so long as the record supports them; and (2) alleged factual misstatements do not warrant reversal where the record shows they were corrected and the sentencing judge ultimately relied on accurate facts tied to deterrence and protection of the public. The decision thus functions as a caution to appellate challengers: identifying an imprecise remark is not enough—procedural unreasonableness requires showing that the sentence was actually built on a materially false foundation or an improper process.