Seriousness of the Offense and Guideline Disparities as a “Sound Reason” to Reject Rule 11(c)(1)(C) Plea Agreements: Commentary on United States v. Lanier (6th Cir. 2025)

Seriousness of the Offense and Guideline Disparities as a “Sound Reason” to Reject Rule 11(c)(1)(C) Plea Agreements: Commentary on United States v. Lanier (6th Cir. 2025)

I. Introduction

In United States v. Christopher Thomas Lanier, No. 25‑3059 (6th Cir. Nov. 20, 2025) (not recommended for publication), the Sixth Circuit addressed a recurring but under‑litigated question: under what circumstances may a district court reject a binding Rule 11(c)(1)(C) plea agreement because the agreed‑upon sentencing range is too lenient compared to the Sentencing Guidelines and the seriousness of the offense?

Christopher Lanier pleaded guilty to two serious federal child‑exploitation offenses: receipt/distribution of child pornography (18 U.S.C. § 2252(a)(2)) and production/sexual exploitation of children (18 U.S.C. § 2251(a)). Under a Rule 11(c)(1)(C) plea agreement, both parties recommended a sentencing range of 292 to 365 months’ imprisonment, with the government agreeing to dismiss a possession count.

After reviewing the presentence report (PSR) and the evidence of Lanier’s conduct—including repeated sexual abuse of a one‑year‑old relative, recording the abuse, and trading the materials for images of abuse of another woman’s children—the district court concluded that the agreed range was grossly below the advisory Guidelines range of 600 months (the combined statutory maximum) and did not adequately reflect the seriousness of the offense. The court rejected the Rule 11(c)(1)(C) agreement, offered Lanier the opportunity to withdraw his plea, and, when he declined, imposed a below‑Guidelines sentence of 420 months.

On appeal, Lanier argued that the district court erred by rejecting the plea without a sufficiently articulated explanation. The Sixth Circuit affirmed. The opinion clarifies within the circuit that:

  • District courts have an affirmative, “independent obligation” to ensure that a binding plea’s sentence is sufficient in light of the Guidelines and 18 U.S.C. § 3553(a);
  • A substantial downward deviation from the advisory Guideline range, absent adequate case‑specific justification, is a sound reason to reject a Rule 11(c)(1)(C) agreement;
  • Plain error review will apply where the defendant fails to object to the rejection of the plea agreement at sentencing;
  • Data about average sentences and victim support for the agreement, standing alone, may be insufficient to justify a significant variance in highly aggravated cases.

II. Summary of the Opinion

A. Factual and Procedural Background

The facts, as summarized by the court, are exceptionally egregious even within the universe of child‑exploitation cases:

  • Lanier repeatedly sexually abused his one‑year‑old relative and recorded the abuse.
  • He sent eleven videos and three images of this abuse to a long‑distance girlfriend, “H.J.”
  • In return, he received sixteen videos and sixteen images of H.J. sexually abusing her own children, which Lanier encouraged and directed—explicitly urging her to rape her youngest daughter.
  • He instructed H.J. to use an encrypted communication platform to conceal their activity.

A federal grand jury indicted Lanier on three counts: receipt/distribution, production/sexual exploitation, and possession of child pornography. Under a Rule 11(c)(1)(C) agreement, Lanier pleaded guilty to the receipt/distribution and production counts; the government agreed to recommend a sentencing range of 292–365 months and to move to dismiss the possession count.

The district court postponed deciding whether to accept the agreement until after reviewing the PSR. The PSR:

  • Described in detail Lanier’s communications and the child‑sexual‑abuse material exchanged;
  • Calculated an advisory Guidelines range of 600 months—the statutory maximum that could lawfully be imposed.

At sentencing, the district judge:

  • Expressed concern that the proposed 292–365 month range was “substantially below” the advisory 600‑month range;
  • Asked both parties twice to justify why that lower range was appropriate, particularly “in light of the seriousness of the offense”; the government offered some justification, but Lanier did not;
  • Took a recess to consider whether to accept the plea in light of the seriousness of the conduct;
  • Ultimately rejected the plea agreement, explaining that the seriousness of Lanier’s conduct outweighed both the arm’s‑length nature of the agreement and the victim’s mother’s support for it.

The court then:

  • Complied with Rule 11(c)(5) by informing Lanier it would not follow the agreement;
  • Advised him of his right to withdraw his guilty plea and warned that he could receive a harsher sentence if he did not withdraw;
  • Accepted Lanier’s decision to stand by his plea and proceed to sentencing;
  • Formally determined that the advisory Guidelines range was 600 months;
  • Imposed a below‑Guidelines sentence of 420 months.

Lanier did not object to the rejection of the plea agreement at the hearing. On appeal, he argued that the district court failed to adequately explain how the seriousness of the offense influenced its decision to reject the agreement—essentially claiming an insufficient statement of reasons.

B. Holding and Disposition

The Sixth Circuit:

  • Applied plain error review (because Lanier did not contemporaneously object to the rejection of the plea);
  • Held that there was no error, let alone plain error, in the district court’s rejection of the Rule 11(c)(1)(C) agreement;
  • Concluded that the district court offered a case‑specific, sound reason for rejection: the agreed range was substantially below the Guidelines and failed to reflect the seriousness of the offense, and the parties offered no persuasive justification for that disparity;
  • Affirmed the district court’s judgment and 420‑month sentence.

III. Analysis

A. Precedents and Authorities Cited

1. Santobello v. New York, 404 U.S. 257 (1971)

The court cites Santobello for the basic principle that district courts have broad discretion in accepting or rejecting plea agreements. While Santobello is best known for enforcing the government’s obligations under a plea bargain, it also acknowledges that the trial judge “may reject” plea arrangements and “is not bound” by the prosecutor’s recommendations (404 U.S. at 262).

In Lanier, this general grant of discretion forms the backdrop: even in a 11(c)(1)(C) context—where an accepted agreement would bind the court—the judge remains free to say “no” at the outset if the contemplated sentence would not serve the purposes of federal sentencing.

2. Freeman v. United States, 564 U.S. 522 (2011) (plurality)

Freeman concerned whether a defendant sentenced under a Rule 11(c)(1)(C) agreement could later seek sentence reduction under 18 U.S.C. § 3582(c)(2) when the applicable Guideline range was lowered. The plurality emphasized that district courts have an “independent obligation” to ensure that a sentence is “sufficient, but not greater than necessary” in light of § 3553(a), and that courts “must consider the Sentencing Guidelines” (564 U.S. at 529).

Lanier uses this language to reinforce that, before accepting a Rule 11(c)(1)(C) sentence, a judge must look beyond the parties’ bargain and independently assess:

  • whether the recommended sentence aligns with the advisory Guidelines, and
  • whether it satisfies § 3553(a)’s purposes (such as reflecting the seriousness of the offense and providing adequate deterrence).

This “independent obligation” is what drives the district court here to demand justification for a substantial downward deviation and, failing that justification, to reject the agreement.

3. Hughes v. United States, 584 U.S. 675 (2018)

Hughes built on Freeman, holding that a sentence imposed under a Rule 11(c)(1)(C) plea is generally “based on” the Guidelines for § 3582(c)(2) purposes when the Guidelines range was part of the sentencing framework. Crucially for Lanier, Hughes also explains that under U.S.S.G. § 6B1.2(c):

  • A court may accept a Rule 11(c)(1)(C) plea only if the agreed sentence is within the applicable Guideline range, or
  • If it is outside the range, there must be “justifiable reasons”, specifically set out, for that variance.

Lanier relies on this framework: the district court was obliged to ensure there were “justifiable reasons” for accepting a sentencing range (292–365 months) that sat far below the 600‑month advisory range. The court asked the parties to articulate those reasons; they offered averages and victim support, which the judge found inadequate. The Sixth Circuit approves this approach as consistent with Hughes.

4. In re United States, 32 F.4th 584 (6th Cir. 2022)

In re United States was a mandamus proceeding where the government challenged a district court’s practice in handling Rule 11(c)(1)(C) agreements. The Sixth Circuit held that:

  • A court that rejects a Rule 11(c)(1)(C) plea must explain why it is doing so (32 F.4th at 594);
  • The explanation must be “sound”—that is, it cannot be arbitrary, invidious, or based on a categorical policy (e.g., reflexively rejecting all such pleas);
  • A key “sound” reason is that the agreement does not “adequately reflect the seriousness of the offense” (id.);
  • The court must conduct an “individualized assessment” of the case, grounded in case‑specific facts, ordinarily informed by the PSR (id. at 595).

Lanier is, in effect, the mirror image of In re United States. The latter faulted a district court for rejecting pleas without case‑specific reasoning; Lanier upholds a rejection where:

  • The judge relied on detailed PSR information and victim impact submissions;
  • Explicitly compared the plea range to the 600‑month advisory range;
  • Identified the “seriousness of the offense” and lack of adequate justification for a large variance as the central reasons;
  • Confirmed that this was not part of any blanket policy (indeed, it was “the first time” the judge rejected this type of agreement for being too lenient).

The panel explicitly invokes In re United States to validate the district court’s rationale: rejecting a plea that does not adequately reflect the seriousness of the offense is categorically a “sound reason.”

5. United States v. Cota‑Luna, 891 F.3d 639 (6th Cir. 2018)

Cota‑Luna likewise addressed a district court’s rejection of a plea agreement. It emphasized that:

  • The court must review the PSR before making a final decision on acceptance or rejection;
  • It must provide a reasoned explanation that is tethered to the specific facts and sentencing considerations.

In Lanier, the district judge complied with this template: reviewing the PSR first, then explicitly tying the rejection to the Guidelines range, the egregious nature of the conduct, and the absence of persuasive mitigation explaining the departure from the Guidelines.

6. United States v. Doggart, 906 F.3d 506 (6th Cir. 2018)

Doggart is cited for the baseline standard of review: ordinarily, a district court’s decision to reject a plea agreement is reviewed for abuse of discretion. This underscores that appellate courts give substantial deference to district judges’ on‑the‑ground assessment of plea bargains and sentencing needs.

7. United States v. Wells, 631 F. App’x 408 (6th Cir. 2015)

Wells clarifies that when a defendant fails to object contemporaneously to the rejection of a plea agreement, appellate review is for plain error, not ordinary abuse of discretion. This is outcome‑determinative in Lanier because the court not only finds no error, but emphasizes that the higher plain‑error standard would be hard to satisfy even had the decision been debatable.

8. Greer v. United States, 593 U.S. 503 (2021)

Greer supplies the familiar four‑part plain‑error test:

  1. There must be an error;
  2. The error must be “plain” (clear or obvious under current law);
  3. The error must affect the defendant’s “substantial rights” (typically, a reasonable probability of a different outcome); and
  4. The error must seriously affect the fairness, integrity, or public reputation of judicial proceedings.

In Lanier, the panel stops at step one: there was no error at all in the district court’s handling of the Rule 11(c)(1)(C) agreement. Thus, the rest of the analysis need not be reached.

B. Legal Reasoning of the Court

1. Standard of Review: Plain Error, Not Abuse of Discretion

A key procedural move is the court’s selection of plain error review. Lanier did not object when the district court rejected the plea agreement, nor did he ask the judge to more fully explain its reasoning. Under Wells, this failure to object triggers plain error review under Greer rather than the more lenient abuse‑of‑discretion standard that typically applies to plea‑rejection decisions (Doggart).

This has practical implications:

  • To win on appeal, Lanier would have had to show not just a debatable or imperfect explanation, but a clear and obvious legal mistake that affected his substantial rights and undermined the integrity of the proceedings.
  • The panel, however, concludes there was no error at all, rendering his challenge untenable irrespective of the elevated standard.

2. The Rule 11(c)(1)(C) Framework and the Court’s “Independent Obligation”

Rule 11 distinguishes among different types of plea agreements. Under Rule 11(c)(1)(C), the parties can agree that a “specific sentence or sentencing range is the appropriate disposition of the case.” If the court accepts that agreement, it is bound by the agreed‑upon sentence or range.

However:

  • The court is never obliged to accept such an agreement; and
  • If it rejects the agreement, Rule 11(c)(5) requires it to:
    • Inform the parties that it rejects the agreement;
    • Advise the defendant that the court is not bound by the agreement;
    • Give the defendant a chance to withdraw the plea;
    • Warn that, if the defendant does not withdraw, the court may impose a more severe sentence.

In addition, as Freeman and Hughes make clear, the court has an independent duty:

  • To ensure that the sentence is “sufficient, but not greater than necessary” to serve § 3553(a)’s goals; and
  • To consider the Guidelines and accept a 11(c)(1)(C) plea only when the sentence is within the Guideline range, or outside it for “justifiable reasons” specifically articulated (U.S.S.G. § 6B1.2(c)).

Applying this framework, the district judge in Lanier correctly:

  • Awaited the PSR before ruling on the agreement (per Cota‑Luna);
  • Noted that the agreed 292–365 month range was substantially below the 600‑month Guidelines range;
  • Asked the parties to “justify” the departure, specifically in light of the “seriousness of the offense” and the need to reconcile the suggested range with § 3553(a);
  • Found the proffered justifications insufficient to constitute the “justifiable reasons” that § 6B1.2(c) requires for a deviation of this magnitude.

3. The District Court’s Explanation: Seriousness, Guideline Disparity, and Lack of Justification

The appellate issue turns on whether the district court provided an adequate, case‑specific explanation for rejecting the plea, as required by In re United States.

The opinion details the district court’s reasoning:

  • The court weighed three competing considerations:
    • “The seriousness of the offense conduct,”
    • The fact that “the parties made an arm’s‑length agreement,” and
    • That “the victim’s mother supported the agreement.”
  • After reviewing the PSR, victim‑impact statements, and sentencing memoranda, the court concluded that the first factor—seriousness—outweighed the latter two.
  • It recognized that the agreed range reflected average sentences for similar Guidelines profiles (around 348–360 months) but reasoned that Lanier was not the “average” offender;
    • He personally sexually abused a one‑year‑old family member;
    • Recorded and distributed the abuse;
    • Actively solicited and directed further abuse of other children by H.J.;
    • Took steps to conceal his wrongdoing through encrypted communications.
  • The court expressly distinguished Lanier’s conduct as “beyond that in a more typical child pornography case.”

The Sixth Circuit treats these as the sort of “case‑specific reasons” that In re United States demands. It also emphasizes that the court:

  • Did not adopt a categorical rule against 11(c)(1)(C) pleas; on the contrary, this was the first such rejection by the judge on these grounds;
  • Anchored its decision in the Guidelines, the PSR, and the particular facts of the offense.

On this record, the panel concludes that the district court satisfied its obligation to explain why it found the agreement too lenient and why it believed no acceptable justification for the large Guideline disparity had been provided.

4. Rejection of the Defendant’s Arguments

Lanier advanced two main arguments on appeal:

  1. The court failed to explain “how the seriousness of the offense impacted its decision to reject the agreement.”
  2. The government had provided adequate reasons to accept the agreement:
    • Sentencing Commission data showing that offenders with his Guidelines profile received average/median sentences around 348–360 months; and
    • The victim’s mother supported the plea range.

The Sixth Circuit rejects the first argument by pointing directly to the sentencing record:

  • The court articulated its concern that the agreed range was “substantially below” the 600‑month advisory range;
  • It repeatedly linked this concern to the “seriousness of the offense conduct,” asking the parties to justify such a gap;
  • It framed the seriousness of the conduct as the dominant factor that outweighed both the arm’s‑length nature of the agreement and the victim’s mother’s support.

As to the second argument, the panel holds that:

  • Average‑sentence data, while relevant, did not compel the district court to treat Lanier as a typical defendant when the facts showed his conduct was substantially more aggravated;
  • The victim’s mother’s support, while properly considered, could not override the judiciary’s independent duty to impose a sentence commensurate with the seriousness of the offense and consistent with § 3553(a);
  • The district court reasonably concluded that neither point adequately justified a sentencing range so far below the Guidelines, particularly in light of the extreme nature of Lanier’s abuse.

Because the district court’s reasons are firmly grounded in the case’s facts and the sentencing framework, the Sixth Circuit finds no error, much less the sort of obvious error that plain‑error review would require.

C. Impact and Implications

1. Reinforcing Judicial Gatekeeping of Rule 11(c)(1)(C) Agreements

Lanier reinforces that, in the Sixth Circuit, trial judges are not mere rubber stamps for negotiated binding plea agreements. Even when both sides vigorously support a Rule 11(c)(1)(C) disposition, the court must:

  • Compare the proposed sentence or range to the applicable Guideline range;
  • Assess whether it “adequately reflects the seriousness of the offense” and other § 3553(a) factors;
  • Require case‑specific justification for any substantial deviation from the Guidelines; and
  • Be prepared to reject the agreement if the justification is lacking.

For prosecutors and defense counsel, this underscores the importance of building a robust, fact‑specific record explaining why a binding plea range may depart upward or downward from the Guidelines, especially in high‑aggravation cases like child exploitation.

2. Limits on Reliance on Averages and Victim Preferences

The decision sends a clear signal that:

  • Sentencing commission statistics—such as average or median sentences for similarly situated offenders—are informative but not dispositive; courts remain obligated to consider whether a defendant’s conduct is worse (or better) than the typical case and sentence accordingly.
  • Victim preferences, including support for a specific plea range, are important but cannot control the sentencing outcome if they conflict with the court’s statutory obligations under § 3553(a).

Practitioners should thus avoid over‑reliance on “average” sentencing data and must be prepared to explain why, in the particular facts of the case, those averages are appropriate—or not.

3. Relationship to In re United States: The “Sound Reason” Requirement

Together with In re United States, Lanier sketches a more complete doctrinal picture:

  • In re United States restricts district courts from rejecting Rule 11(c)(1)(C) pleas based on categorical policies or unexplained dissatisfaction; they must offer sound, individualized reasons.
  • Lanier confirms that a plea range that is markedly below the Guidelines, in a case involving unusually serious offense conduct, may itself be a sound, case‑specific reason for rejection—provided the court articulates this on the record.

In this sense, Lanier does not announce an entirely new rule but concretely applies and illustrates the “sound reason, individualized assessment” standard in the specific context of an exceptionally aggravated child‑exploitation case.

4. Preservation and Appellate Review of Plea‑Rejection Decisions

The case also highlights the importance of preservation. Defendants (and counsel) who believe a court is mishandling a Rule 11(c)(1)(C) agreement must:

  • Object contemporaneously to the rejection or insufficient explanation; or
  • Request further elaboration on the record.

Failure to object, as in Lanier, will subject any later challenge to plain‑error review—a demanding standard under which many close or arguable issues will never be reached, because the appellate court will not disturb the judgment absent clear and obvious error affecting substantial rights.

5. Practical Takeaways for Child‑Exploitation and Other High‑Aggravation Cases

Although unpublished and thus not binding precedent within the Sixth Circuit, Lanier has obvious persuasive force for similar cases:

  • In highly aggravated child‑exploitation prosecutions, district courts are particularly likely to scrutinize any binding plea that recommends a sentence substantially below the maximum‑driven Guidelines range.
  • Parties seeking such a plea must be prepared with strong, individualized reasons (e.g., substantial cooperation, unusual mitigation, evidentiary problems, or other compelling § 3553(a) considerations).
  • Merely pointing to “average” sentences for comparable Guidelines scores or to victim acquiescence is unlikely to suffice where the specific facts show extreme abuse.

At the same time, the 420‑month sentence imposed—still 180 months below the 600‑month advisory range—illustrates that:

  • Rejection of a Rule 11(c)(1)(C) plea does not necessarily signal that the court will impose the maximum sentence;
  • Rather, it reflects the court’s insistence that it, not the parties, retains ultimate responsibility for calibrating a just punishment within the statutory and Guidelines framework.

IV. Complex Concepts Simplified

1. Rule 11(c)(1)(C) Plea Agreements (“C‑Pleas”)

Under Federal Rule of Criminal Procedure 11(c)(1)(C), the prosecution and defense can agree that a specific sentence or sentencing range is the “appropriate disposition” of the case. If the judge accepts this type of agreement:

  • The judge is bound by the agreed sentence or range and may not go above or below it.

However:

  • The judge is not required to accept the agreement; and
  • If the judge rejects it, the defendant has the right to withdraw the plea.

2. Advisory Sentencing Guidelines and the 600‑Month Range

The federal Sentencing Guidelines are a detailed set of rules that suggest a sentencing range based on the offense and the defendant’s criminal history. Since United States v. Booker (2005), they are advisory, not mandatory, but courts must calculate and consider them.

In this case, the PSR calculated an advisory Guidelines range of 600 months—essentially the combined statutory maximum for the offenses. This means:

  • Under the Guidelines’ rules and enhancements, a 50‑year sentence was the recommended upper limit;
  • The district court could not lawfully go higher, as it would exceed statutory maximums for the counts of conviction.

3. 18 U.S.C. § 3553(a): The Sentencing Factors

Section 3553(a) lists factors courts must consider when imposing sentence, including:

  • The nature and circumstances of the offense and the history and characteristics of the defendant;
  • The need for the sentence to:
    • Reflect the seriousness of the offense,
    • Promote respect for the law,
    • Provide just punishment,
    • Afford adequate deterrence,
    • Protect the public, and
    • Provide needed educational/vocational training or medical care;
  • The kinds of sentences and sentencing ranges established by the Guidelines;
  • The need to avoid unwarranted sentence disparities among similar defendants.

Judges must ensure that the sentence is “sufficient, but not greater than necessary” to satisfy these purposes.

4. Plain Error Review

Plain error review applies when a party fails to object in the trial court. To obtain relief, the appellant must show:

  1. There was a legal error;
  2. The error was “plain” (clear or obvious at the time of appeal);
  3. The error affected substantial rights (typically requiring a reasonable probability of a different result); and
  4. The error seriously affected the fairness, integrity, or public reputation of judicial proceedings.

It is a demanding standard. In Lanier, the court finds no error at all, so the analysis ends at step one.

5. U.S.S.G. § 6B1.2(c): Acceptance of Plea Agreements

Section 6B1.2(c) of the Guidelines Policy Statements governs when courts may accept plea agreements that specify a sentence or range:

  • The court may accept the agreement if the agreed sentence is within the applicable Guidelines range; or
  • If the sentence is outside the range, the court may accept only if there are “justifiable reasons” for the departure or variance, and those reasons are stated with specificity.

This is the provision that underlies the district court’s insistence on a persuasive explanation for a 292–365 month range in a 600‑month case—and its eventual rejection when such justification was not forthcoming.

V. Conclusion

United States v. Lanier provides a concrete application of the Sixth Circuit’s emerging jurisprudence on Rule 11(c)(1)(C) agreements, as shaped by Freeman, Hughes, Cota‑Luna, and In re United States. While unpublished, the opinion underscores several important points:

  • District courts possess, and must exercise, meaningful discretion when asked to bind themselves to a negotiated sentencing range;
  • They have an independent obligation to measure any proposed 11(c)(1)(C) range against the advisory Guidelines and § 3553(a);
  • A major downward deviation from the Guidelines, especially in a case involving extreme child sexual exploitation, requires strong, case‑specific justification;
  • Average sentencing statistics and victim support for a plea agreement, while relevant, may not suffice to justify such a variance where the conduct is markedly more egregious than the norm;
  • When a defendant fails to object to a plea’s rejection, any appellate challenge will face the steep climb of plain error review.

Ultimately, Lanier confirms that “seriousness of the offense” and a substantial, unexplained disparity with the Guidelines are valid, “sound” reasons for rejecting a binding plea, so long as the district court articulates its reasoning with reference to the facts of the case and the sentencing framework. It thus reinforces the judiciary’s gatekeeping role in plea‑driven sentencing and provides practical guidance to practitioners structuring Rule 11(c)(1)(C) agreements in serious federal cases.

Case Details

Year: 2025
Court: Court of Appeals for the Sixth Circuit

Comments