Section 3582(a) Bars Imprisonment Lengths for Rehabilitation: United States v. Culberson

Introduction

United States v. Rashaud Roosevelt Culberson, decided by the Sixth Circuit on April 22, 2025, addresses the scope of a district court’s authority under 18 U.S.C. § 3582(a) and § 3553(a)(2)(D) when considering rehabilitation in sentencing. The defendant, a Michigan resident with a significant criminal history, was convicted by a jury of being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)) and pled guilty to possessing contraband (fentanyl) while in federal custody (18 U.S.C. §§ 1791(a)(2), (b)(1), (c)). At sentencing, the district court imposed concurrent terms at the bottom of the Guidelines ranges: 41 months for the firearms conviction and 12 months for the contraband conviction. Culberson appealed the 41-month term as substantively unreasonable, alleging that the court impermissibly considered his rehabilitative needs and overemphasized his criminal history.

Summary of the Judgment

The Sixth Circuit affirmed. It held that:

Under 18 U.S.C. § 3582(a), a sentencing court “shall consider” § 3553(a) factors but must recognize that “imprisonment is not an appropriate means of promoting correction and rehabilitation.” A district court may inform a defendant of prison-based programs without violating this bar.
Unlike in Tapia v. United States and United States v. Rucker, the district court did not tie the 41-month term to eligibility for any specific rehabilitative program. Its comments merely encouraged participation in counseling and vocational training available in federal prison.
The within-Guidelines sentence is presumptively reasonable, and Culberson failed to rebut that presumption. The court gave proper weight to § 3553(a) factors, including his serious criminal history, life circumstances, and need for deterrence and public protection.

Analysis

Precedents Cited

The opinion extensively discusses and distinguishes three key precedents:

Tapia v. United States, 564 U.S. 319 (2011)
Held that § 3582(a)’s “recognizing” clause prevents a court from imposing or lengthening a prison term to promote rehabilitation, e.g., selecting a term solely to qualify a defendant for in-prison programs.
United States v. Rucker, 874 F.3d 485 (6th Cir. 2017)
Reinforced Tapia by reversing a sentence where the district court explicitly chose 22 months so the defendant would enter a drug-abuse program.
United States v. Deen, 706 F.3d 760 (6th Cir. 2013)
Emphasized that a sentence may not be imposed “to enable an offender to complete a treatment program or otherwise to promote rehabilitation inside a prison’s walls.”

Legal Reasoning

The Sixth Circuit applied the deferential abuse-of-discretion standard for within-Guidelines sentences. It first laid out the statutory framework:

§ 3553(a) lists factors a court “shall consider,” including (a)(2)(D): “the need to provide the defendant with needed educational or vocational training, medical care, or other correctional treatment.”
§ 3582(a) carves out a specific limitation: “recognizing that imprisonment is not an appropriate means of promoting correction and rehabilitation.”

The court then examined the sentencing transcript. While the district judge encouraged Culberson to use prison resources for self-improvement, there was no statement linking the term’s length to program eligibility. By contrast, in Tapia and Rucker the courts selected terms to meet program-length thresholds. Here, the judge chose the bottom of the Guidelines range based on the § 3553(a) factors—seriousness of offense, deterrence, public protection, and Culberson’s personal history.

The court further held that because the sentence fell within the Guidelines range, it was presumptively reasonable. Culberson did not show that the district court gave an unreasonable amount of weight to any factor or ignored relevant factors.

Impact

United States v. Culberson provides clarity to sentencing courts in the Sixth Circuit (and persuasively to others) about how to discuss rehabilitation. Its key contributions:

Reinforces that § 3582(a) prohibits basing the length of a prison sentence on rehabilitation goals, but does not forbid encouraging a defendant to use prison-based programs.
Clarifies the distinction between permissible “exhortation” about available services and impermissible “program-tied” sentencing.
Affirms that a within-Guidelines sentence remains presumptively reasonable absent a clear abuse of discretion.

Future district courts should take care to avoid any linkage in their reasoning between sentence length and program eligibility—and appellate courts will scrutinize any suggestion that a term was selected to “enable completion” of treatment.

Complex Concepts Simplified

Section 3553(a) Factors: A list of considerations (seriousness, deterrence, public protection, rehabilitation, etc.) that a court “shall consider” when sentencing.
Section 3582(a) “Recognizing” Clause: A statutory command that, although courts must consider § 3553(a), they must recognize that imprisonment is not appropriate for rehabilitation purposes.
Substantive vs. Procedural Reasonableness: Procedural focuses on process (calculation, consideration of factors), substantive on the sentence’s length relative to the goals of sentencing.
Presumptive Reasonableness: Under Gall v. United States, within-Guidelines sentences are presumed reasonable, placing the burden on the defendant to show an abuse of discretion.

Conclusion

United States v. Culberson cements the principle that sentencing courts must not impose or extend prison terms for the purpose of rehabilitation, in line with § 3582(a) and Tapia. At the same time, judges remain free to inform defendants of available rehabilitative programs without making those opportunities the driving force behind the term imposed. Finally, the decision underscores the Sixth Circuit’s strong deference to within-Guidelines sentences when the district court has thoughtfully balanced the § 3553(a) factors.